United States v. Angelo Williams: Terse Sentencing Explanations Suffice for Within-Guidelines Sentences under Steiger

Introduction

United States v. Angelo Williams, No. 24-11023 (11th Cir. July 7, 2025) is an unpublished but instructive decision that both re-affirms the evidentiary latitude afforded to the government in proving firearm possession through circumstantial evidence and, more pointedly, clarifies—post United States v. Steiger (en banc 2024)—the level of articulation a district court must give when imposing a within-Guidelines sentence. Although the Government sought an upward variance, the district court sentenced Williams at the top of the advisory range (51 months), and the Eleventh Circuit held that the court’s brief, record-anchored explanation satisfied § 3553(c) because the sentence was inside the Guidelines and the case was “conceptually simple.”

The appeal arose from a § 922(g)(1) conviction, following a domestic-violence incident in which police recovered an AK-47-type rifle from a rental car occupied by the defendant and his former girlfriend. Williams challenged (1) the sufficiency of the evidence of possession, and (2) the procedural and substantive reasonableness of his sentence. Both arguments failed.

Summary of the Judgment

Conviction affirmed: Circumstantial evidence—particularly the temporal proximity between Williams loading his luggage and the officers finding the weapon underneath those bags—was sufficient for a reasonable jury to infer actual possession.
Sentence affirmed: The Eleventh Circuit found no plain error in the district court’s succinct explanation and no abuse of discretion in the 51-month sentence, which sat at the top of, but within, the Guidelines range (41–51 months) and far below the 10-year statutory maximum.

Analysis

A. Precedents Cited

United States v. Steiger, 99 F.4th 1316 (11th Cir. 2024) (en banc) – re-iterates that “conceptually simple” cases with within-Guidelines sentences do not require extensive on-the-record reasoning so long as it is evident the judge considered the arguments and § 3553(a) factors.
Rita v. United States, 551 U.S. 335 (2007) & Chavez-Mesa v. United States, 585 U.S. 109 (2018) – provide the Supreme Court framework permitting brief explanations when Guidelines are followed.
Gall v. United States, 552 U.S. 38 (2007) – establishes abuse-of-discretion review and the heightened explanation requirement for major variances; used to contrast the present within-range sentence.
United States v. Fries, 725 F.3d 1286 (11th Cir. 2013) – articulates the “record devoid” and “shocking” standards governing sufficiency challenges not preserved below (plain-error/post-trial motion contexts).
United States v. Howard, 742 F.3d 1334 (11th Cir. 2014) & United States v. Derose, 74 F.3d 1177 (11th Cir. 1996) – address circumstantial proof and definitions of actual versus constructive possession.
United States v. Irey, 612 F.3d 1160 (11th Cir. 2010) (en banc) – supplies the “definite and firm conviction” standard for substantive reasonableness.

B. Legal Reasoning

Possession Proven by Circumstantial Evidence
The court emphasized that eyewitness testimony of gun handling is unnecessary. Evidence that (a) the back seat had been empty when the girlfriend returned, (b) Williams personally loaded suitcases, and (c) the rifle barrel protruded from beneath those same bags minutes later, is enough for a rational jury. Add to this corroboration that the weapon matched one sold to a coworker named “Angelo,” and Williams’s pre-move-in admission that he owned a gun, and the plain-error burden (“record devoid” or “shocking”) is not met.
Plain-Error Hurdle for Unpreserved Sufficiency Claims
Because Williams never made a Rule 29 motion, he faced the Eleventh Circuit’s most deferential sufficiency standard. This procedural nuance alone doomed his attack: a reviewing court will seldom overturn a jury verdict when any record evidence can support it.
Sentencing Explanation Post-Steiger
The district judge expressly adopted the PSR, listened to competing variance requests, referenced several § 3553(a) factors, and stated the Guidelines sentence was “appropriate” in view of both aggravating and mitigating facts. Under Steiger, that suffices for a “conceptually simple” case and within-range sentence; a fuller discourse is reserved for major departures.
Substantive Reasonableness Analysis
The panel gave deference to the district court’s weighing of violent conduct, history of probation violations, and deterrence needs over the defendant’s evidence of post-arrest rehabilitation. The 51-month term sat at the upper end of the advisory range but remained well below the statutory maximum of 10 years for § 922(g)(1), which militated toward reasonableness.

C. Impact of the Judgment

Sentencing Stage: District courts in the Eleventh Circuit can confidently rely on brief, record-grounded explanations for within-Guidelines sentences post-Steiger. Defense counsel must now anticipate that appeals premised on “brevity” alone will be uphill battles.
Evidentiary Burdens: The case reinforces that circumstantial chains—especially ones involving temporal proximity and exclusive access—remain potent proof of actual possession. Practitioners should treat physical handling evidence as helpful but not indispensable.
Strategic Imperative for Rule 29 Motions: Failing to move for acquittal leaves defendants stuck with a plain-error lens on appeal. Counsel should preserve sufficiency issues early or face the near-insurmountable “record devoid” hurdle.
Plea-versus-Trial Calculus: The opinion signals that even top-of-Guidelines sentences may survive scrutiny absent a procedural defect, influencing risk assessments at plea negotiations.

Complex Concepts Simplified

Plain-Error Review: A four-part appellate test applied when trial objections were not preserved. The error must be obvious (“plain”), affect substantial rights, and impair the integrity of the proceedings.
Actual vs. Constructive Possession: “Actual” means physical control; “constructive” means power and intention to control. Either suffices under § 922(g). Here, the finding of the gun under Williams’s luggage created an inference of actual possession.
Within-Guidelines Sentence: A term of imprisonment that falls inside the sentencing range calculated under the U.S. Sentencing Guidelines. Such sentences are afforded “ordinary” but not “binding” deference on appeal.
§ 3553(a) Factors: Congressional checklist guiding federal sentencing. They include the seriousness of the offense, deterrence, public protection, defendant’s history and characteristics, and the need to avoid unwarranted disparities.
Conceptually Simple Case: One where the facts, Guidelines calculation, and arguments do not involve unusual complexity, allowing a shorter sentencing explanation to meet statutory requirements.

Conclusion

Although United States v. Angelo Williams is unpublished, it operates as a practical roadmap for prosecutors, defense attorneys, and district courts alike. The Eleventh Circuit underscored two principal lessons:

In § 922(g) prosecutions, circumstantial evidence—particularly when woven with corroborative statements and temporal proximity—can robustly sustain a jury finding of possession.
After Steiger, a brief, fact-anchored explanation will normally pass procedural muster for a within-Guidelines sentence; defendants seeking reversal must show more than judicial concision.

Going forward, counsel must recognize the high bar to overturn sufficiency findings not preserved by a Rule 29 motion and should expect limited appellate relief where district courts impose within-range sentences after acknowledging the record and § 3553(a) considerations, even in only a few measured sentences.