United States v. Bryan Ledbetter

• Court: Court of Appeals for the Fourth Circuit
• Decided: June 26, 2025
• Docket: 24-4338
• Status: Unpublished

Opinion

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UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 24-4338

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

BRYAN DEQUAN LEDBETTER,

Defendant - Appellant.

Appeal from the United States District Court for the Western District of North Carolina, at Charlotte. Robert J. Conrad, Jr., District Judge. (3:22-cr-00274-RJC-SCR-1)

Submitted: March 28, 2025 Decided: June 26, 2025

Before WYNN, HARRIS, and BENJAMIN, Circuit Judges.

Affirmed by unpublished per curiam opinion.

ON BRIEF: John G. Baker, Federal Public Defender, Ann L. Hester, Assistant Federal Public Defender, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Charlotte, North Carolina, for Appellant. Dena J. King, United States Attorney, Elizabeth M. Greenough, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Charlotte, North Carolina, for Appellee.

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PER CURIAM:

Bryan Dequan Ledbetter pled guilty to possession of a firearm by a convicted felon,

in violation of 18 U.S.C. §§ 922(g)(1), 924(a)(8). The district court sentenced Ledbetter

above his advisory Sentencing Guidelines range to 96 months’ imprisonment. On appeal,

Ledbetter argues that his sentence is procedurally unreasonable because the district court

failed to address his nonfrivolous argument for a lower sentence based on his employment

history and work ethic. Finding no reversible error, we affirm.

We review a criminal sentence, “whether inside, just outside, or significantly

outside the Guidelines range,” for reasonableness “under a deferential abuse-of-discretion

standard.” Gall v. United States, 552 U.S. 38, 41 (2007); see United States v. Lewis, 18

F.4th 743, 748 (4th Cir. 2021). We must first “evaluate procedural reasonableness,

determining whether the district court committed any procedural error, such as improperly

calculating the Guidelines range, failing to consider the [18 U.S.C.] § 3553(a) factors, or

failing to adequately explain the chosen sentence.” United States v. Nance, 957 F.3d 204,

212 (4th Cir. 2020).

For a sentence to be procedurally reasonable, “a district court must conduct an

individualized assessment of the facts and arguments presented and impose an appropriate

sentence, and it must explain the sentence chosen.” Id. (internal quotation marks omitted).

Relevant here, “a district court must address or consider all non-frivolous reasons presented

for imposing a different sentence and explain why [it] has rejected those arguments.”

United States v. Ross, 912 F.3d 740, 744 (4th Cir. 2019). A district court satisfies this

requirement “if it, although somewhat briefly, outlines the defendant’s particular history

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and characteristics not merely in passing or after the fact, but as part of its analysis of the

statutory factors and in response to defense counsel’s arguments for a [lower sentence].”

United States v. Lozano, 962 F.3d 773, 782 (4th Cir. 2020) (internal quotation marks

omitted). A “[d]istrict court[] need not spell out [its] responses to [the] defendant[’s]

arguments where context makes them clear. But the context must make it patently obvious

that the district court found the defendant’s arguments to be unpersuasive.” Id. (cleaned

up). Moreover, as long as the “district court addresses a defendant’s central thesis, it need

not address separately every specific claim made in support.” United States v. Powers, 40

F.4th 129, 137 (4th Cir. 2022) (cleaned up).

On appeal, Ledbetter contends that his sentence is procedurally unreasonable

because, although the district court explained its reasons for imposing an upward variant

sentence, the court failed to address his nonfrivolous arguments for a within-Guidelines

sentence predicated on his employment history and work ethic. Specifically, Ledbetter

asserts that, while his sentencing memorandum mainly focused on his mental health issues,

a licensed psychologist’s report and two character letters were included that referenced

Ledbetter’s work history and work ethic. Additionally, Ledbetter notes that his work

history was mentioned briefly in the presentence report, as well as during his allocution.

Ledbetter contends that these references to his work history and work ethic constituted an

independent nonfrivolous mitigation argument that the court failed to address, resulting in

a procedurally unreasonable sentence.

Our review of the record confirms that the district court thoroughly explained its

reasons for imposing an upward variance. The court noted that it had considered all of the

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memoranda and letters submitted, as well as defense counsel’s arguments in opposition to

an upward variance. When imposing the sentence, the court recognized Ledbetter’s

difficult childhood and that recent trauma and mental health and substance abuse issues

likely played a role in his conduct. However, the court found that an upward variant

sentence was warranted in light of Ledbetter’s underrepresented criminal history, his

violent conduct against the same victim, and his danger to the public. While the court did

not explicitly address Ledbetter’s work history or work ethic, it was not required to do so

as Ledbetter did not clearly present work history as a standalone mitigation argument, and

certainly not as his central thesis. See Powers, 40 F.4th at 137. As Ledbetter acknowledges

in his opening brief, his primary argument at sentencing was regarding his recent mental

health diagnoses and how proper treatment would make him unlikely to reoffend, which

the court addressed. We therefore conclude that Ledbetter’s sentence is procedurally

reasonable.

Accordingly, we affirm the judgment of the district court. We dispense with oral

argument because the facts and legal contentions are adequately presented in the materials

before this court and argument would not aid the decisional process.

AFFIRMED