United States v. Barnett: Intertwined § 3553(a) Analysis as Adequate Explanation for Consecutive Federal Sentences

I. Introduction

In United States v. Chase Allen Barnett, the United States Court of Appeals for the Sixth Circuit addressed how thoroughly a district court must explain its reasons for imposing a consecutive federal sentence when a defendant is already serving (or is about to serve) undischarged state sentences arising from parole or probation revocations. The decision sits at the intersection of:

• the statutory framework of federal sentencing under 18 U.S.C. §§ 3553(a) and 3584(a);
• the advisory policy statements in U.S.S.G. §5G1.3(d) and its commentary; and
• the appellate concepts of procedural reasonableness and plain-error review where the defendant did not object in the trial court.

Barnett had pled guilty to serious federal drug offenses involving methamphetamine and fentanyl. At the time of federal sentencing, he already faced substantial state prison time due to revoked parole and probation in Kentucky and Indiana stemming from prior drug and firearm felonies. The district court imposed a substantial downward variance from the advisory guideline range but ordered that the federal sentence run consecutively to his undischarged state sentences.

On appeal, Barnett did not challenge the length of the sentence as such. Instead, he argued that the district court failed to adequately explain why the federal sentence had to be consecutive rather than concurrent. Because he had not objected to this aspect of his sentence at the time of sentencing, the appellate court reviewed his claim only for plain error.

The Sixth Circuit affirmed. It held that the district court’s explanation—though brief and intertwined with its overall discussion of the § 3553(a) factors—was sufficient, particularly when viewed against:

• the guideline commentary that favors consecutive sentencing when state time is due to revocations, and
• the deferential plain-error standard.

Although the opinion is designated “Not Recommended for Publication,” it reinforces and synthesizes a line of Sixth Circuit authority on what counts as an adequate explanation for consecutive sentences, especially under plain-error review.

II. Summary of the Opinion

The panel (Judges Moore, Thapar, and Ritz, with Judge Ritz writing) framed a single issue: whether the district court “imposed a consecutive sentence without adequate explanation.” The court:

1. Held that, because Barnett did not object at sentencing to the consecutive nature of the sentence, the appellate standard of review was plain error (citing United States v. Brown, 131 F.4th 337 (6th Cir. 2025); United States v. Wallace, 597 F.3d 794 (6th Cir. 2010); and United States v. Vonner, 516 F.3d 382 (6th Cir. 2008) (en banc)).
2. Reiterated that a consecutive sentence is unreasonable if the district court fails to adequately explain why it is consecutive, but that “adequate explanation” can be provided through an intertwined, holistic discussion of the § 3553(a) factors and does not require “magic words” or a separate, freestanding analysis (citing, among others, United States v. Berry, 565 F.3d 332 (6th Cir. 2009); United States v. Cochrane, 702 F.3d 334 (6th Cir. 2012); United States v. Johnson, 640 F.3d 195 (6th Cir. 2011); and United States v. Miller, Nos. 23‑5270/5436, 2025 WL 459648 (6th Cir. Feb. 11, 2025)).
3. Emphasized the advisory guideline commentary in §5G1.3(d), Application Note 4(C), which specifically recommends that federal sentences be imposed consecutively when the defendant’s undischarged terms of imprisonment result from revocations of probation or parole. That commentary directly applied to Barnett’s situation.
4. Concluded that the district court’s explanation—discussing the seriousness of Barnett’s conduct, his escalating criminal behavior, the danger posed by fentanyl, the need to protect the public, to provide treatment, and to temper justice with mercy—when coupled with the downward variance and the guideline policy favoring a consecutive sentence, made the rationale for the consecutive nature of the sentence “generally clear.”
5. Held that, under these circumstances, there was no plain error and affirmed the sentence.

In short, the court confirmed that an intertwined discussion of the § 3553(a) factors and sentencing policy, followed by the declaration that the sentence will be consecutive, can suffice as an adequate explanation for a consecutive sentence—especially where the guidelines themselves counsel a consecutive sentence and the defendant failed to object.

III. Detailed Analysis

A. Factual and Procedural Background

1. The underlying conduct and state cases

In February 2023, Barnett sold methamphetamine and fentanyl to a confidential informant. Federal prosecutors charged him with four counts under 21 U.S.C. § 841(a)(1), the principal federal drug-trafficking statute. At that time:

• Barnett already had prior felony drug and firearm convictions.
• Those priors had led to conditional release in the form of probation and parole in Indiana and Kentucky, respectively.
• As a result of new violations, Kentucky and Indiana had revoked his parole and probation, issuing warrants and subjecting him to additional state incarceration.
• In Kentucky, his parole revocation and new state offenses exposed him to a custodial term extending at least until 2032.

Thus, by the time of federal sentencing, Barnett faced a stacking problem: state sentences from revocations plus a new federal sentence arising from the same broad pattern of continued criminal behavior.

2. The guideline range and district court’s sentence

Barnett pled guilty to all four federal counts without a plea agreement. The presentence report calculated an advisory guideline range of 262 to 327 months. The probation office recommended that this federal term run consecutively to any sentence in the Kentucky and Indiana cases, consistent with U.S.S.G. §5G1.3(d) and its commentary.

At sentencing, the district court engaged in an extensive colloquy:

• It heard from the government about Barnett’s “pattern of criminal activity” and the escalating nature of his conduct.
• It heard from Barnett regarding his profoundly traumatic childhood (including sexual abuse and domestic violence) and his serious and life-threatening health conditions.
• The court acknowledged the extreme danger posed by distributing fentanyl, noting that substances like fentanyl are “killing people like flies.”
• At the same time, the court expressed sadness and empathy for Barnett’s background, acknowledging the difficulty of “formulat[ing] a sentence that is not greater than necessary” while still protecting the public and providing “much-needed” mental health and addiction treatment.

Balancing these considerations, the court:

• Imposed a sentence of 200 months on each count, concurrent with each other.
• Made that 200-month term run consecutively to any sentence imposed in the Kentucky and Indiana state cases.

This sentence represented:

• a downward variance of more than five years below the low end of the guideline range (262 → 200 months), and
• more than ten years below the government’s requested sentence of 327 months.

Barnett’s principal federal sentencing request had two parts: (1) a large downward variance, and (2) a federal sentence that was concurrent with his state time. The court honored the first request in significant measure (a substantial variance), but rejected the second (it ordered consecutivity).

3. The appeal

On appeal, Barnett did not claim that the length of 200 months was substantively unreasonable in itself. Instead, his argument was more technical: the district court, he asserted, had failed to adequately explain its reason for imposing the sentence consecutively rather than concurrently.

Critically, Barnett did not object to the consecutive nature of the sentence at the time of sentencing. This procedural fact dictated a plain-error standard of review, which in turn raised the bar for reversal.

B. Standard of Review: Plain Error

Ordinarily, sentences are reviewed for abuse of discretion, which includes both:

• Procedural reasonableness (focusing on method—did the court correctly calculate the guideline range, treat the guidelines as advisory, consider § 3553(a) factors, avoid clearly erroneous fact-finding, and explain the sentence?), and
• Substantive reasonableness (focusing on outcome—was the sentence reasonable in light of the statutory factors?).

Here, however, Barnett did not preserve his specific complaint by objecting to the consecutive nature of the sentence. The Sixth Circuit applied plain-error review, following:

• United States v. King, 914 F.3d 1021 (6th Cir. 2019) (ordinary abuse-of-discretion review when properly preserved);
• United States v. Brown, 131 F.4th 337 (6th Cir. 2025) (plain-error framework in sentencing context);
• United States v. Wallace, 597 F.3d 794 (6th Cir. 2010); and
• United States v. Vonner, 516 F.3d 382 (6th Cir. 2008) (en banc).

Under plain-error review, the defendant must show:

1. there was an error;
2. the error was “plain” (i.e., clear or obvious under current law);
3. the error affected substantial rights (usually, a reasonable probability of a different outcome); and
4. the error seriously affected the fairness, integrity, or public reputation of judicial proceedings.

Meeting this four-part test is difficult. For Barnett to prevail, he had to demonstrate not merely that the explanation for consecutivity was imperfect, but that any inadequacy was plainly erroneous, prejudicial, and corrosive to the integrity of the process. The panel held he failed to do so.

C. The Framework for Concurrent vs. Consecutive Sentences

1. Statutory discretion: 18 U.S.C. § 3584(a)

Section 3584(a) codifies a sentencing judge’s discretion when a defendant faces multiple terms of imprisonment:

• The judge may order them to run concurrently (at the same time) or consecutively (one after the other).
• In exercising that discretion, the court must consider the familiar sentencing factors in 18 U.S.C. § 3553(a).

In cases like Barnett’s—where the defendant already has (or is subject to) undischarged state terms—§ 3584(a) gives the federal court a choice: stack time on top of the state sentence, overlap it in whole or in part, or run it entirely concurrently. But that choice must be guided by § 3553(a) and any relevant policy statements in the Sentencing Guidelines.

2. Guidelines and policy statements: U.S.S.G. §5G1.3(d)

U.S.S.G. §5G1.3 addresses how federal courts should structure sentences in the presence of undischarged terms of imprisonment. Subsection (d) is a catch-all provision covering situations not covered by its other subsections. Crucially, the commentary to §5G1.3(d), Application Note 4(C), states (as summarized by the Barnett panel) that when a defendant is:

subject to “undischarged terms of imprisonment resulting from revocations of probation [or] parole . . . the sentence for the instant offense [should] be imposed consecutively to the sentence imposed for the revocation.”

Thus, in a case like Barnett’s—where his undischarged state sentences flowed from revocations of probation or parole—the guidelines specifically counsel a consecutive federal sentence. That guidance is not mandatory in the post‑Booker era, but it is an important policy marker that district courts must at least consider.

3. The requirement to explain

Even with this discretion and guidance, a district court must still explain its choice. Sixth Circuit law holds:

• A consecutive sentence is unreasonable if the district court fails to adequately explain why the sentence is consecutive. (United States v. Perez‑Rios, 846 F. App’x 371, 372 (6th Cir. 2021), citing United States v. Cochrane, 702 F.3d 334 (6th Cir. 2012)).
• However, “adequate” explanation does not mean a separate, formalistic recital for consecutivity. District courts:
  • must “indicate on the record [their] rationale, either expressly or by reference to a discussion of relevant considerations contained elsewhere” (Cochrane, 702 F.3d at 346);
  • are not required to state a specific, stand-alone reason for a consecutive sentence (United States v. Johnson, 640 F.3d 195, 208–09 (6th Cir. 2011)); and
  • “need not conduct a separate Section 3553(a) analysis for the concurrent or consecutive nature of the sentence” (United States v. Miller, Nos. 23‑5270/5436, 2025 WL 459648, at *13 (6th Cir. Feb. 11, 2025) (quoting Berry, 565 F.3d at 343)).

In short, the law requires a reasoned basis for the choice, but allows that basis to be conveyed through an integrated discussion of the § 3553(a) factors and the overall sentencing rationale.

D. Precedents Cited and Their Influence

1. Gall and the general sentencing framework

The panel cites Gall v. United States, 552 U.S. 38 (2007), and United States v. Solano‑Rosales, 781 F.3d 345 (6th Cir. 2015), for the standard dual inquiry into procedural and substantive reasonableness. Gall is the foundational Supreme Court case affirming that:

• The guidelines are advisory.
• District courts must consider them, along with § 3553(a), and explain their reasoning.
• Appellate courts must apply an abuse-of-discretion standard and give deference to within- and below-guidelines sentences, so long as the method is sound.

While Gall did not concern consecutive vs. concurrent sentencing specifically, it supplies the doctrinal backbone: sentencing decisions are reviewed holistically, and explanation is required but does not need to be mechanical.

2. Berry, Cochrane, and Perez‑Rios: explaining consecutive sentences

The panel draws heavily from a line of Sixth Circuit authority wrestling with the explanation requirement in the concurrent/consecutive context:

• United States v. Berry, 565 F.3d 332 (6th Cir. 2009):
  • Observed that challenges to concurrent vs. consecutive decisions are not easily classified as purely “substantive” or purely “procedural,” because the substantive reasonableness of a consecutive decision depends on whether the procedural explanation was adequate.
  • Stated that district courts need not perform a separate § 3553(a) analysis solely for the concurrent/consecutive decision, so long as their overall reasoning makes the rationale clear.
  • That proposition is explicitly reaffirmed in Barnett through a citation to Miller, which in turn quotes Berry.
• United States v. Cochrane, 702 F.3d 334 (6th Cir. 2012):
  • Held that a district court must at least “indicate on the record its rationale, either expressly or by reference to a discussion of relevant considerations contained elsewhere.”
  • One aspect of Cochrane was later abrogated by the Supreme Court’s decision in Rodriguez v. United States, 575 U.S. 348 (2015), but not the explanatory principle that Barnett applies.
  • Barnett relies on Cochrane specifically for the articulation of how a court may “incorporate by reference” its earlier § 3553(a) discussion to justify consecutive time.
• United States v. Perez‑Rios, 846 F. App’x 371 (6th Cir. 2021):
  • Restated the rule that a consecutive sentence is unreasonable if the district court fails to adequately explain why it is consecutive.
  • Confirmed that when a defendant has an undischarged state sentence, the district court has discretion under § 3584(a) to order concurrent, partially concurrent, or consecutive time.
  • Emphasized the need to consider § 3553(a) and relevant guideline policy statements, including §5G1.3(d).

Barnett uses these cases to frame the issue as one of explanation sufficiency rather than whether the court was permitted to impose a consecutive sentence at all. It signals continuity with the principle that some explanation is required but how much is context-dependent and evaluated with deference, especially on plain-error review.

3. Johnson, Owens, and “no magic words”

The panel underscores that district courts are not required to utter “magic words” to justify consecutivity:

• United States v. Johnson, 640 F.3d 195 (6th Cir. 2011):
  • Held that there is “no requirement that the district court state a specific reason for a consecutive sentence.”
  • It suffices that the reason is “generally clear” from the broader sentencing discussion.
• United States v. Owens, 159 F.3d 221 (6th Cir. 1998):
  • Earlier case cited in Johnson (and through it, in Barnett) for the “generally clear” standard: if the record as a whole makes the rationale apparent, a more granular or segmented explanation is unnecessary.

Barnett applies this standard directly, saying the district court made it “generally clear” why it imposed a consecutive sentence by:

• highlighting the seriousness of Barnett’s conduct and escalating criminal behavior;
• recognizing the danger to the community, particularly the lethality of fentanyl;
• balancing these concerns against his traumatic personal history and treatment needs; and
• coupling a significant downward variance with adherence to guideline policy favoring consecutivity.

4. Miller and Kitchen: no separate § 3553(a) analysis needed

The panel also references:

• United States v. Miller, Nos. 23‑5270/5436, 2025 WL 459648 (6th Cir. Feb. 11, 2025):
  • Quoted for the proposition that district courts “need not . . . conduct a separate Section 3553(a) analysis for the concurrent or consecutive nature of the sentence” (quoting Berry).
  • Thus, Barnett aligns itself with the view that the decision on consecutivity can be integrated into the main sentencing explanation, rather than treated as a freestanding, separately explained component.
• United States v. Kitchen, 428 F. App’x 593 (6th Cir. 2011):
  • Held that a district court does not plainly err when it imposes a consecutive sentence “in conjunction with or immediately following the court’s invocation of the § 3553(a) factors.”
  • This, too, is echoed in Barnett: the court notes that what happened at Barnett’s sentencing—an integrated discussion followed by a declaration that the sentence would be consecutive—is precisely what Kitchen approves.

5. Brown, Wallace, and Vonner: plain-error doctrine in sentencing

The court draws upon:

• United States v. Brown, 131 F.4th 337 (6th Cir. 2025):
  • For the proposition that failure to object below limits the defendant to plain-error review.
  • The Barnett opinion also uses Brown’s language noting a district court “hastened to add” the consecutive nature of a sentence, suggesting that timing and manner of the announcement can support an inference that consecutivity is part of the same considered judgment as the § 3553(a) analysis.
• United States v. Wallace, 597 F.3d 794 (6th Cir. 2010) and United States v. Vonner, 516 F.3d 382 (6th Cir. 2008) (en banc):
  • Provide the four-part plain-error test.
  • Emphasize that appellate courts are particularly reluctant to reverse on unpreserved procedural claims when the district court gave any meaningful explanation and the overall sentence is otherwise plausible under § 3553(a).

Together, these cases shape Barnett’s core holding: once the reviewing court is in plain-error territory, only a clearly deficient or missing explanation would warrant reversal. Here, by contrast, the explanation was present, integrated, and aligned with guideline policy.

E. Legal Reasoning Applied to Barnett

1. The role of U.S.S.G. §5G1.3(d) cmt. n.4(C)

A significant part of the panel’s reasoning is that the Guidelines themselves strongly favored a consecutive sentence in Barnett’s situation. Application Note 4(C) to §5G1.3(d) recommends that when a defendant is serving undischarged terms of imprisonment resulting from probation or parole revocations, the new sentence “be imposed consecutively” to the revocation term.

Barnett conceded that this commentary applied. That concession means:

• The district court was presumptively justified in choosing a consecutive sentence.
• The burden on the defendant to show that the court’s explanation for following that default policy was plainly inadequate became significantly heavier.

The panel effectively reasons that, given:

• the guideline policy favoring consecutivity,
• the court’s clear recognition of the seriousness of Barnett’s offense and the danger to the public,
• the fact that the court had already reduced the sentence length substantially below the guideline range to show “mercy,” and
• the integrated explanation referencing § 3553(a) factors,

the district court’s decision to make the federal sentence consecutive was a “logical extension” of its sentencing rationale. Put differently, once the court had already taken account of Barnett’s personal circumstances and granted a large variance, it could reasonably view consecutivity as the mechanism through which it preserved respect for the law and accounted for the distinct harms reflected in his state revocation sentences.

2. Intertwining § 3553(a) analysis with the consecutive decision

The district court’s explanation of the sentence included:

• Concern for the escalating nature of Barnett’s drug trafficking and its consequences for public safety (seriousness of the offense, need to protect the public, and to deter);
• Acknowledgment that fentanyl trafficking endangers the community in an acute way (“killing people like flies”);
• Recognition of Barnett’s traumatic background and health struggles and the need for treatment, which supported leniency in terms of the sentence length and the court’s desire to “temper[] justice with some mercy”; and
• Discussion of the need to craft a sentence “not greater than necessary,” tracking the language of § 3553(a).

After giving this explanation—addressing the key § 3553(a) factors—the court imposed 200 months, substantially below the guideline minimum, and “hastened to add” that the federal sentence would run consecutively to the state sentences.

Under the authorities discussed above (Berry, Johnson, Owens, Miller, Kitchen), the panel held that this methodology satisfied the requirement of an adequate explanation:

• No separate, siloed § 3553(a) analysis for consecutivity was required.
• The reasons for both the length of the sentence and its consecutive nature could be drawn from the same integrated discussion.
• The explanation need only be “generally clear,” which, in the panel’s view, it was.

3. Why there was no “plain error”

Even if one could imagine a more detailed explanation specifically focused on why the sentence had to be consecutive (e.g., explicit reference to §5G1.3(d) note 4(C) on the record, or a formal juxtaposition of alternative concurrent structures), the plain-error standard asks whether the absence of such elaboration was:

• clearly erroneous under existing law,
• outcome-determinative, and
• so serious that it undermined the integrity or public reputation of the proceedings.

The panel answered “no” on these points because:

• Current Sixth Circuit law expressly allows intertwined explanations and rejects any requirement for a separate consecutive-sentence analysis.
• The guideline policy unambiguously favored a consecutive sentence in Barnett’s posture.
• The district court provided a careful and sympathetic explanation overall, which reduced rather than aggravated his time relative to the guidelines.
• The declared consecutivity was logically linked to that reasoning—it was not an unexplained or arbitrary afterthought.

Accordingly, even if defense counsel might have preferred more express reasoning about concurrency vs. consecutivity, the panel found no plain error.

F. Impact and Significance

1. Practical guidance for district courts

Although unpublished and not precedential, Barnett offers practical lessons:

• Integrated explanation suffices. District judges can justify a consecutive sentence by embedding their rationale within the broader § 3553(a) discussion, so long as:
  • they articulate the key factors (seriousness, deterrence, protection of the public, defendant’s history and characteristics, etc.), and
  • the reasons for consecutivity are reasonably inferable from that same explanation.
• Explicit reference to guideline policy helps but is not mandatory. Where §5G1.3(d) commentary favors a consecutive approach, citing it explicitly can strengthen the record, but even implicit reliance—paired with a clear recognition of the nature of the prior revocation sentences—can be enough.
• Downward variances can coexist with consecutivity. The case illustrates that granting a substantial downward variance on the term’s length does not obligate a court to run the sentence concurrently. Consecutive structure can be the tool by which the court acknowledges separate harms and preserves deterrence and public safety while still showing mercy.

2. Strategic lessons for defense counsel

For defense practitioners, Barnett underscores several strategic points:

• Preserve objections. If a defendant wants to argue on appeal that the court inadequately explained a consecutive sentence, counsel should object at sentencing. Failure to do so triggers plain-error review, a highly deferential standard that is very difficult to satisfy.
• Address §5G1.3(d) head-on. Where revocations are involved, defense counsel should:
  • anticipate the guideline presumption of consecutivity, and
  • develop arguments why, in the specific case, concurrency would still be “sufficient but not greater than necessary,” possibly pointing to unique rehabilitation prospects, overlapping culpability, or mitigating personal circumstances.
• Request specific findings if concurrency is critical. If concurrency is a central objective, counsel may wish to explicitly ask the court to articulate on the record why concurrency is rejected (if it is), preserving a clearer appellate issue.

3. Doctrinal clarification within the Sixth Circuit

The opinion consolidates and restates a line of Sixth Circuit authority on consecutive sentences:

• It reaffirms that the adequacy of explanation is the focal point for reviewing consecutive sentences.
• It clarifies that this explanation:
  • need not be segregated from the overall § 3553(a) discussion;
  • need only be “generally clear” when viewed in context; and
  • is especially insulated from reversal when the defendant forfeited the issue in the district court.
• It gives additional weight to §5G1.3(d) cmt. n.4(C) in revocation-related contexts, reinforcing the presumption that consecutive sentencing is the norm in such scenarios.

While it does not dramatically change the law, it offers a clear and current synthesis, particularly valuable because it:

• integrates older cases like Owens and Johnson with more recent ones like Miller and Brown, and
• demonstrates how courts apply these principles in a modern fentanyl-trafficking case paired with state revocations.

IV. Complex Concepts Simplified

1. Concurrent vs. Consecutive Sentences

• Concurrent sentences run at the same time. If a person has a 10-year state sentence and a 10-year federal sentence that are fully concurrent, the total time in custody can be as little as 10 years (subject to credit rules).
• Consecutive sentences run back-to-back. The same 10-year state and 10-year federal terms, if fully consecutive, add up to effectively 20 years.

Which structure a court chooses can dramatically change how long a defendant remains in prison, even if the nominal length of each sentence stays the same.

2. Undischarged Term of Imprisonment

An “undischarged term of imprisonment” means a sentence the defendant is currently serving or still subject to. For example:

• A defendant on state parole who gets revoked and ordered to serve the remainder of the state term.
• A defendant on suspended sentence or probation who is then revoked and sent to prison.

When a federal court sentences someone who already has such undischarged terms, § 3584(a) and §5G1.3(d) guide the judge in deciding how to align the new federal time with the existing state time.

3. Plain-Error Review

Plain-error review is a stricter form of appellate scrutiny used when the defendant did not properly object in the trial court. To win under plain error, a defendant must prove:

1. An error occurred (the court did something wrong under the law);
2. The error was “plain” (clear or obvious);
3. The error affected substantial rights (likely would have changed the outcome); and
4. Failure to correct it would seriously harm the fairness, integrity, or reputation of the judicial process.

In practice, this is a very demanding standard. Many arguable procedural missteps do not meet it.

4. Procedural vs. Substantive Reasonableness

• Procedural reasonableness concerns how the court sentenced:
  • Did it correctly calculate the guideline range?
  • Did it treat the guidelines as advisory?
  • Did it consider the § 3553(a) factors?
  • Did it adequately explain its reasons for the sentence?
• Substantive reasonableness concerns what the sentence is:
  • Is the length of the sentence reasonable in light of the § 3553(a) factors?
  • Is the balance among deterrence, punishment, rehabilitation, and public safety appropriately struck?

Challenges to consecutive vs. concurrent decisions often blend these concepts because the substantive unreasonableness of a consecutive sentence can turn on whether the court gave an adequate procedural explanation for making it consecutive.

5. Guidelines Policy Statements vs. Binding Rules

Since United States v. Booker, 543 U.S. 220 (2005), the Sentencing Guidelines (including policy statements like §5G1.3(d)) are advisory rather than mandatory. That means:

• Courts must consider the guidelines and explain any major variances.
• But they are not strictly required to follow every guideline or commentary note.
• Nonetheless, when the guidelines speak clearly to a situation—such as recommending consecutive sentences for revocation-related undischarged terms—courts treat that as important guidance, and departing from it calls for a reasoned explanation.

V. Conclusion

United States v. Barnett reinforces a key principle of federal sentencing practice in the Sixth Circuit: a district court may justify a consecutive sentence through an integrated, holistic discussion of the § 3553(a) factors, without a separate, elaborate analysis devoted solely to the question of concurrency vs. consecutivity, particularly where the Sentencing Guidelines themselves support a consecutive approach and the defendant has not preserved the issue.

The case illustrates how a court can:

• recognize a defendant’s traumatic background and serious health issues;
• grant a significant downward variance to reflect “mercy” and treatment needs;
• yet still impose a consecutive sentence to protect the public and acknowledge the gravity of ongoing criminal conduct, especially in the high-risk context of fentanyl trafficking.

By synthesizing older and more recent Sixth Circuit precedents, Barnett clarifies for trial judges and practitioners alike that:

• the key to appellate sustainability is a clear, coherent explanation anchored in § 3553(a);
• consecutive sentencing, especially where revocation-based undischarged terms are involved, is well supported by guideline policy; and
• unpreserved objections face a steep uphill climb on appeal under plain-error review.

Although not a published opinion, Barnett serves as a robust and current guidepost on how courts within the Sixth Circuit should articulate and defend the imposition of consecutive federal sentences in the shadow of undischarged state revocation terms.