“Minimal-Explanation Suffices” – The Sixth Circuit’s Clarification on Consecutive Revocation Sentences in United States v. Daniel Lamor Major

Introduction

The Sixth Circuit’s unpublished opinion in United States v. Daniel Lamor Major, No. 24-5605 (6th Cir. 2025), addresses the procedural-reasonableness requirements that govern sentences imposed after the revocation of supervised release. Daniel Major—already facing 140 months for fresh drug-conspiracy convictions—received an additional 33 months for violating the terms of a prior supervision period. On appeal, he claimed the district court gave an insufficient explanation for (1) running the 33 months consecutively and (2) fixing the length at 33 months. The Sixth Circuit affirmed, holding that:

A district court need not give a detailed on-the-record analysis when it selects a Guidelines-range sentence recommended by both parties, and
Merely referencing that the sentence is “consistent with the Guidelines” can satisfy the duty to explain a consecutive revocation sentence because U.S.S.G. § 7B1.3(f) presumes consecutivity.

The decision clarifies that, in the revocation context, a “minimal but discernible” explanation will often survive appellate scrutiny—especially where the defendant’s own recommendation matches the imposed sentence.

Summary of the Judgment

• Background: Major was near the end of a five-year supervised-release term stemming from 2010 gun and cocaine offenses.
• New Charges: In July 2022 he was indicted for a large fentanyl/meth conspiracy and ultimately sentenced to 140 months.
• Revocation: The same conduct—and several earlier marijuana, reporting, and state-charge violations—triggered revocation proceedings. The advisory range under Chapter 7 was 33–41 months.
• District Court: Both sides urged a low-end 33-month term; the dispute was only whether it should be concurrent. Citing “multiple violations” and the Chapter 7 policy statement, the court imposed 33 months consecutive to the 140.
• Appeal: Major argued the district court (i) failed to address his chief mitigation argument (the warrant issued mere days before supervision expired) and (ii) inadequately explained the 33-month length.
• Holding: No procedural error—the court expressly acknowledged the timing argument, implicitly relied on § 7B1.3(f) for consecutivity, adopted the parties’ joint low-end recommendation, and therefore met its explanatory burden.

Analysis

1. Precedents Cited

Gall v. United States, 552 U.S. 38 (2007) – foundational framework for procedural reasonableness.
Rita v. United States, 551 U.S. 338 (2007) – appellate deference where court “sets forth enough.”
United States v. Bolds, 511 F.3d 568 (6th Cir. 2007) – abuse-of-discretion review of revocation sentences.
United States v. Richardson, 437 F.3d 550 (6th Cir. 2006) – duty to address non-frivolous arguments.
United States v. Gunter, 620 F.3d 642 (6th Cir. 2010) – “look to what the court did, not only what it said.”
United States v. King, 914 F.3d 1021 (6th Cir. 2019) – explicit citation to § 7B1.3(f) not mandatory if reasoning clear.
Recent circuit authority on revocation procedure: United States v. Thomas-Mathews, 81 F.4th 530 (6th Cir. 2023); United States v. Mills, 126 F.4th 470 (6th Cir. 2025); United States v. Adams, 124 F.4th 432 (6th Cir. 2024).

These cases collectively shaped the standard: the sentencing judge must calculate the Guidelines range, consider the § 3553(a) factors, respond to principal arguments, and create an adequate record—yet the formality required scales with context.

2. Legal Reasoning of the Court

The panel applied a two-step procedural-reasonableness inquiry:

Was each non-frivolous argument addressed?
– Yes. The transcript shows the judge expressly referenced Major’s “better argument” claim but discounted it due to “multiple violations,” satisfying Richardson.
Was the explanation of the sentence (both length and consecutivity) adequate?
– For consecutivity: The judge said the sentence was “consistent with the guidelines.” Because § 7B1.3(f) default-rules consecutive terms, the Sixth Circuit deemed the reference sufficient under King.
– For length: Both sides asked for 33 months at the low end of the 33–41 range; thus the court’s single-sentence adoption (“sufficient but not greater than necessary”) was enough under Rita and Jeross.

The panel emphasized that sentencing explanations are “contextual.” When: (i) the court selects a within-Guidelines sentence, (ii) the parties jointly request it, and (iii) no unique factual controversies exist, only a brief statement is required.

3. Potential Impact

District-Court Practice: Judges may confidently rely on § 7B1.3(f) to impose consecutive revocation sentences without incanting the policy statement verbatim. A succinct reference to “the guidelines” and a nod to the § 3553(a) purposes can suffice.
Defense Strategy: Defendants hoping for concurrency must do more than invoke the timing of the warrant; they must either rebut § 7B1.3(f)’s presumption (e.g., extraordinary circumstances) or persuade the court to vary downward from the advisory range.
Appellate Review: The decision reinforces deferential abuse-of-discretion review even when the district court’s explanation is terse, as long as the record as a whole “makes sense.”
Guidelines Interpretation: Although § 7B1.3(f) is technically a “policy statement,” the panel’s willingness to treat it as effectively controlling elevates its practical force.

Complex Concepts Simplified

Supervised Release: A post-imprisonment monitoring period in the federal system. Violation can lead to additional imprisonment.
Revocation Hearing: A proceeding where the court decides whether the defendant breached release conditions and what sanction to impose.
Consecutive vs. Concurrent: Consecutive sentences are served back-to-back; concurrent sentences run at the same time.
Procedural Reasonableness: Focuses on how the court arrived at the sentence (calculated range, considered arguments, explained decision), not how long the sentence is.
U.S.S.G. § 7B1.3(f): A Sentencing Guidelines policy statement that recommends any prison term for a supervised-release violation be served consecutively to any current term.
Abuse-of-Discretion Review: The appellate court defers unless the lower court used the wrong legal standard, mis-applied it, or relied on clearly erroneous facts.

Conclusion

United States v. Daniel Lamor Major reinforces a pragmatic principle: when a district court selects a within-Guidelines, party-recommended sentence and gestures to the relevant policy statement, an extensive on-the-record explanation is unnecessary. By upholding the consecutive 33-month revocation term, the Sixth Circuit underscores § 7B1.3(f)’s force and clarifies appellate expectations. The ruling will guide both trial judges—who may streamline revocation hearings where the facts are undisputed—and advocates—who must craft more persuasive reasons if they seek an atypical outcome such as concurrency or a below-range sentence.