United States v. Christner: Plain–Error Review Governs Unobjected § 3553(c) Errors and a Single Statement Suffices for Both Custodial and Supervised-Release Terms

1. Introduction

In United States v. Michael Thomas Christner, No. 24-13229 (11th Cir. May 13, 2025) (unpublished), the Eleventh Circuit confronted the sentencing of a recidivist child-sex offender who received a 360-month custodial sentence followed by lifetime supervised release. The appeal raised two questions:

• Whether the district court procedurally erred by failing to articulate separate reasons for the lifetime supervised-release term as required by 18 U.S.C. § 3553(c).
• Whether the lifetime supervised-release term was substantively unreasonable under the 18 U.S.C. § 3553(a) factors.

The Eleventh Circuit affirmed. In doing so, it highlighted two doctrinal clarifications:

1. Standard of Review: In light of the en banc decision in United States v. Steiger, 99 F.4th 1316 (11th Cir. 2024), unobjected-to § 3553(c) errors are reviewed only for plain error.
2. Scope of Explanation: § 3553(c) does not require a district court to provide separate justifications for imprisonment and supervised release; a unified explanation of the overall sentence is sufficient. This re-affirms the panel’s earlier unpublished reasoning in United States v. Hamilton, 66 F.4th 1267 (11th Cir. 2023).

2. Summary of the Judgment

Michael Thomas Christner, already a convicted sex offender, was caught in a federal sting after soliciting sex from an undercover agent posing as a 15-year-old boy on the dating application “Daddyhunt.” He pleaded guilty to:

• Attempted enticement of a minor (18 U.S.C. § 2422(b)); and
• Commission of a sex offense against a minor while a registered sex offender (18 U.S.C. § 2260A).

The Presentence Investigation Report (PSR) set a guideline range of 235–293 months plus a mandatory consecutive 120-month term, and advised that § 3583(k) required 5 years to life of supervised release. The parties agreed to 360 months’ imprisonment but argued supervised release separately. The district court imposed lifetime supervision without individualised verbal justification apart from its global discussion of the § 3553(a) factors.

On appeal, Christner argued procedural error and substantive unreasonableness. Applying Steiger’s plain-error rubric and relying heavily on Hamilton, the panel found:

• No plain procedural error because the district court’s global explanation sufficed for both imprisonment and supervision.
• No substantive error because a life term lies within the statutory and guideline range (5 years to life) and was reasonably justified by Christner’s recidivism, the heinous nature of child-sex crimes, and the need to protect the public.

The sentence was therefore affirmed in full.

3. Analysis

3.1 Precedents Cited

• United States v. Steiger, 99 F.4th 1316 (11th Cir. 2024) (en banc)
  Re-aligned Eleventh Circuit law with Supreme Court precedent by holding that mistakes not raised at sentencing—including § 3553(c) omissions—are reviewed under the four-part plain-error test (Olano). Christner applies this holding as binding authority.
• United States v. Hamilton, 66 F.4th 1267 (11th Cir. 2023)
  Recognised that § 3553(c) does not compel separate explanations for supervised release. Hamilton is treated favorably for its substantive reasoning although its de novo review language is disclaimed by Steiger.
• Rita v. United States, 551 U.S. 338 (2007)
  Requires the sentencing court to show it has considered the parties’ arguments and has a reasoned basis. Cited for the proposition that the explanation need only be adequate, not elaborate.
• Gall v. United States, 552 U.S. 38 (2007) and Shaw / Sarras
  Provide the backdrop for substantive-reasonableness review, emphasising deference and the special severity of child-sex crimes.

3.2 Legal Reasoning

1. Procedural Reasonableness
   a) Under § 3553(c)(1) a district court must state its reasons for the chosen sentence where the custodial term exceeds 24 months.
   b) Christner clarifies that § 3553(c) does not contain a further, freestanding obligation to justify supervised release separately.
   c) The district court’s recital of: (i) the graphic nature of Christner’s communications; (ii) his 9.3-year prior term for similar conduct; and (iii) the need to protect children, was a “sufficient explanation” that applied to all components of the sentence.
   d) Any failure to elaborate further was, at worst, forfeited and subject to plain-error review; under Steiger, the appellant could not meet Olano’s third & fourth prongs.
2. Substantive Reasonableness
   a) The life-time term fell squarely within § 3583(k)’s 5-to-life range; such sentences enjoy a presumption of reasonableness.
   b) The court’s heavy weight to the defendant’s recidivism and the gravity of child-sex offences was permissible; courts may give “great weight” to a single § 3553(a) factor (Shaw).
   c) The offender’s letters in mitigation, while considered, were outweighed by the need for deterrence and protection of the public.
   d) Comparison arguments (Christner’s crimes being “less severe” than other § 3583(k) predicates) were rejected because § 3583(k) treats them equivalently and the totality of circumstances controlled.

3.3 Impact on Future Litigation

• Standard-of-Review Clarity: Defense counsel must now object contemporaneously to any alleged § 3553(c) shortfall; failing to do so will trigger plain-error review, an almost insurmountable hurdle.
• Unified Explanation Endorsed: Sentencing judges in the Eleventh Circuit need not craft separate, itemised explanations for supervised release, so long as the record shows a reasoned basis for the overall sentence.
• Child-Sex-Offense Sentencing: The court’s endorsement of lifetime supervision for a repeat offender underscores the Circuit’s willingness to impose—and affirm—the upper statutory limit when recidivism and public-safety concerns are acute.
• Guideline Reliance Strengthened: The panel re-iterates that sentences within guideline and statutory ranges are ordinarily reasonable, bolstering prosecutorial arguments for life-time terms where § 3583(k) applies.

4. Complex Concepts Simplified

• Supervised Release: A court-ordered period of monitoring after prison. Unlike probation, it follows a custodial sentence and is designed to ease reintegration and protect the public.
• § 3553(c) Statement of Reasons: The sentencing judge must explain the chosen sentence sufficiently for appellate review. The explanation can be brief if the context is clear.
• Plain-Error Review: A four-pronged appellate standard (error, plainness, substantial-rights impact, and effect on judicial integrity) that is very difficult for appellants to satisfy.
• Lifetime Supervised Release: The statutory maximum term of supervision under § 3583(k) for certain sex-offence convictions. Imposed where courts believe risk persists indefinitely.
• Guidelines vs. Statutory Range: The Sentencing Guidelines provide advisory ranges; the statute sets hard minimums/maximums. A within-statutory, within-guideline sentence is presumptively reasonable.

5. Conclusion

United States v. Christner cements two procedural rules in the Eleventh Circuit:

1. Any unpreserved claim that the district court failed to comply with § 3553(c) is subject to the stringent plain-error standard clarified by the Court’s en banc decision in Steiger.
2. A district court’s single, holistic explanation of the sentence satisfies § 3553(c) for both imprisonment and supervised release; separate treatment is not required.

Beyond these procedural holdings, the decision showcases the circuit’s continued intolerance of recidivist child-sex offenders and willingness to affirm the most severe supervisory terms available under federal law. Practitioners should take note: timely objections at sentencing are indispensable, and arguments for leniency in child-sex-crime cases must confront the judiciary’s emphatic focus on deterrence and public protection.