Eleventh Circuit Court of Appeals - Published Opinions

Friday, February 10, 2006

Williams: Sentence "in violation of law" when court gives no reasons for it

In U.S. v. Williams, No. 04-14350 (Feb. 8, 2006), the Court affirmed a conviction and rejected four of five challenges to the sentence. However, the Court agreed with the defendant that the district court erred, when imposing sentence, in failing to comply with 18 U.S.C. § 3553(c)(1), which requires the court, at the time of sentencing, "to state in open court the reasons for its imposition of the particular sentence, and, if the sentence . . . exceeds 24 months, the reason for imposing a sentence at a particular point within the [Guideline] range."
The Court rejected the government’s argument that this error was subject only to "plain error" review. Citing U.S. v. Veteto, 920 F.2d 824 (11th Cir. 1991), the Court noted that failure to comply with the statement of reasons requirement of § 3553(c)(1) results in a sentence imposed "in violation of law." "Here the trial court offered no reason for the life sentence it elected to impose upon 26-year old Williams." The Court therefore remanded the case to the district court.