United States v. Gray: Appellate Deference to District-Court Findings on Bureau-of-Prisons Medical Capability in Supervised-Release Revocations

Introduction

In United States v. Christopher Kirk Gray, No. 24-4420 (4th Cir. July 8, 2025) (unpublished), the Fourth Circuit affirmed a 48-month term of imprisonment imposed after the revocation of Gray’s supervised release. The appeal raised two central issues:

• Procedural Reasonableness. Did the district court clearly err in finding that the Bureau of Prisons (“BOP”) could adequately treat Gray’s rare cancer?
• Substantive Reasonableness. Did the court give disproportionate weight to incarceration relative to the need for medical care, thus rendering the sentence unreasonable?

Although the opinion is unpublished and therefore non-precedential in the Fourth Circuit, it articulates and synthesizes principles that will likely guide future litigants and district judges on how appellate courts scrutinize medical-care arguments at revocation sentencings.

Summary of the Judgment

The Fourth Circuit, in a per curiam decision, held:

• The district court did not commit clear error in concluding—after hearing live testimony from a BOP physician—that the BOP could continue Gray’s cancer treatment and necessary monitoring.
• The 48-month sentence, which fell below the advisory Chapter 7 policy-statement range (51–60 months) and well within the statutory maximum, was substantively reasonable. The sentencing court permissibly balanced Gray’s medical needs against repeated supervised-release violations involving large-scale methamphetamine trafficking.

Consequently, the Fourth Circuit affirmed, emphasizing the “broad discretion” afforded to district courts in revocation contexts and the deferential “plainly unreasonable” standard of appellate review.

Analysis

A. Precedents Cited

The panel anchored its reasoning in a line of Fourth Circuit cases that establish the analytical framework for revocation sentences:

• United States v. Patterson, 957 F.3d 426 (4th Cir. 2020) – Sets out the two-step inquiry (“unreasonable” then “plainly unreasonable”) and defines the deferential posture on appeal.
• United States v. Padgett, 788 F.3d 370 (4th Cir. 2015) – Confirms that though the § 3553(a) factors apply, appellate review is more deferential than in initial sentencings.
• United States v. Coston, 964 F.3d 289 (4th Cir. 2020) – Explains requirements for procedural reasonableness in revocation settings.
• United States v. Slappy, 872 F.3d 202 (4th Cir. 2017); United States v. Gibbs, 897 F.3d 199 (4th Cir. 2018) – Clarify the scope of explanation necessary for meaningful appellate review.
• United States v. Cox, 744 F.3d 305 (4th Cir. 2014) – Articulates the clear-error standard for factual findings and the permissibility of relying on hearsay with “indicia of reliability.”
• United States v. Jeffery, 631 F.3d 669 (4th Cir. 2011); United States v. Friend, 2 F.4th 369 (4th Cir. 2021) – Stress the wide latitude given to sentencing courts in weighing § 3553(a) factors.
• United States v. Louthian, 756 F.3d 295 (4th Cir. 2014) – Recognizes the presumption of reasonableness for sentences within (or below) the advisory range.

Collectively, these cases supplied the doctrinal scaffolding for the panel’s conclusion that neither procedural nor substantive error was present.

B. Legal Reasoning of the Court

1. Procedural Review.
   • The district court relied on testimony from a BOP physician who had reviewed Gray’s records, consulted with a BOP oncologist, and testified that:
     • The BOP could procure Gray’s current medication.
     • On-site and off-site specialists would be available for monitoring and procedures.
     • Treatment interruptions would be avoided.
   • Because factual findings at sentencing need only be supported by a preponderance of the evidence, and because reliable hearsay is admissible, the Fourth Circuit found no clear error in the court’s acceptance of the physician’s testimony.
2. Substantive Review.
   • The district court balanced:
     • Gray’s “serious medical needs.”
     • The nature and extent of the supervised-release violations (large-scale meth distribution).
     • The need to deter recidivism and protect the public.
     • The advisory policy-statement range.
   • Because the sentence was below the advisory range and grounded in permissible considerations, the appellate court presumed it reasonable. Gray’s disagreement with factor-weighting did not suffice to rebut that presumption.
3. Standard of Appellate Deference. The panel reiterated that it may overturn a revocation sentence only when the error is “clear or obvious.” The court thus refused to substitute its judgment for the district court’s once it found the district judge’s factual findings and balancing exercises fell within the wide zone of reasonableness.

C. Likely Impact of the Decision

Although unpublished, the decision crystallizes several practical points that will influence future litigation:

• Medical-Care Objections Must Be Specific and Evidentially Robust. Merely asserting that a medical condition is “unique” will not suffice; defendants should be prepared to submit competing expert testimony undermining BOP capabilities.
• Increased Reliance on BOP Physician Testimony. The Fourth Circuit signaled its willingness to accept such testimony—so long as it carries indicia of reliability—as a sufficient basis for factual findings.
• Continued Strength of the Presumption of Reasonableness. Even in revocation contexts, sentences within or below the Chapter 7 range enjoy strong appellate insulation.
• Reaffirmation of “Breach-of-Trust” Purpose. The court underscored that revocation penalties serve to punish the breach itself, distinct from the underlying offense conduct.

Complex Concepts Simplified

• Revocation Sentence. A punishment imposed when a person on supervised release violates its terms; it is distinct from the original sentence for the underlying crime.
• Chapter 7 Policy Statement Range. Non-binding advisory ranges in the Sentencing Guidelines that help courts determine appropriate penalties for supervised-release violations.
• Procedurally vs. Substantively Unreasonable.
  • Procedural Unreasonableness concerns the process: whether correct law was applied, proper factors considered, and findings adequately explained.
  • Substantive Unreasonableness questions the length of the sentence itself, asking whether, given all circumstances, the punishment is overly harsh or lenient.
• Plainly Unreasonable Standard. Even if a sentence is found unreasonable, the appellate court must ask whether the error is “plain”—i.e., obvious—to reverse.
• Breach of Trust. The Sentencing Commission explains that the central aim of revocation is punishing the defendant’s violation of the court’s trust, not necessarily replicating punishment for the underlying criminal conduct.
• Clear Error. A high bar for appellate reversal of factual findings: the appellate court must be “left with the definite and firm conviction” that a mistake was made.

Conclusion

United States v. Gray reinforces the Fourth Circuit’s highly deferential review of revocation sentences, particularly where medical-care claims are advanced. The decision confirms that:

1. District courts may rely on BOP medical testimony, even if hearsay, when it bears sufficient reliability.
2. Sentences within or below the advisory Chapter 7 range remain presumptively reasonable.
3. The appellate “plainly unreasonable” lens makes reversal unlikely absent demonstrable procedural defects or dramatic substantive imbalance.

For practitioners, the opinion signals that future challenges to revocation sentences on medical-care grounds will require comprehensive, concrete evidence questioning BOP capabilities. Absent such evidence, the district court’s factual findings and weighing of § 3553(a) factors will almost certainly stand.