United States v. James Williams

In United States v. Williams, No. 23-50725 (5th Cir. Aug. 1, 2024) (unpublished), the Fifth Circuit vacated the defendant’s revocation sentence because the district court had “committed plain error by relying on clearly erroneous facts in arriving at the sentence.”

After a revocation hearing, the district court imposed an above-Guidelines sentence of 36 months in prison. The court’s reasons included that it had “seen him once before,” and he “fail[ed] to support his children, as required by [the sentencing judge].”

On appeal, Williams argued that those two claims were factually incorrect, and the Government agreed: “his sentence had not been previously revoked, and no evidence in the record suggests that Williams failed to pay child support. Williams had also not previously appeared before this sentencing judge.”

The Fifth Circuit rejected the Government’s argument that these were merely “inartful” comments open to “reasonable debate.” Instead, the court held, “they plainly evince that the court relied on clearly erroneous facts in sentencing Williams.” “And because the court sentenced Williams to an above-guidelines sentence, that error affected his substantial rights,” so the court vacated his sentence and remanded his case for resentencing.