United States v. Abney, 957 F.3d 241 (D.C. Cir. 2020). A defendant has a right to make a statement before being sentenced for violating probation or supervised release. The defendant preserved his objection to the denial of this right by informing the sentencing court that he wanted to “say something.” Even assuming that the error was unpreserved, the failure to permit a defendant to speak before sentencing would be plain error.
United States v. Lawrence, 1 F.4th 40 (D.C. Cir. 2021). Federal Rule of Criminal Procedure 43 explicitly makes clear that the right to allocute does not apply to sentence reduction proceedings.