Tenth Circuit - Sentencing Procedure

United States v. Begay, 974 F.3d 1172 (10th Cir. 2020). A court may not consider federal/state sentencing disparities under 18 U.S.C. § 3553(a)(6). A sentencing-disparity claim may be relevant to other § 3553(a) factors, but the defendant did not sufficiently brief the argument.

United States v. Lawless, 979 F.3d 849 (10th Cir. 2020). In an arson case where the defendant built and planted bombs in three public places at night and his conduct resulted in no injuries, an upward variance from 60 months to 144 months was procedurally and substantively reasonable.

Training Topic: