Holguin-Hernandez v. United States, 140 S.Ct. 762 (2020). A defendant is not required to refer to the “reasonableness” of his revocation sentence to preserve the claim for appeal. By advocating for a shorter sentence, a defendant preserves the claim that a longer sentence is unreasonable.
Davis v. United States, 140 S. Ct. 1060 (2020). Plain error review applies to unpreserved factual arguments as well as unpreserved legal arguments.