United States v. Mattea

The DC Circuit affirmed defendant's 151 month sentence after he pleaded guilty to the distribution of child pornography. The court held that the district court did not abuse its discretion when applying the two-level computer-use enhancement under USSG 2G2.2(b)(6); the district court adequately considered the need to avoid unwarranted disparities and did not abuse its discretion when concluding that defendant was differently situated from defendants for whom other district court judges granted downward variances; the district court did not procedurally err when invoking the particular characteristics of defendant's offense to justify his sentence; the district court considered the aspects of defendant's crime that justified the disparity between his within-Guidelines sentence and the below-Guidelines sentences in this circuit; challenged statements did not detract from the district court's reasoned consideration of defendant's arguments for a downward variance; and the within-Guidelines sentence was substantively reasonable. View "United States v. Mattea" on Justia Law