United States v. Lorenzo Watson

• Court: Court of Appeals for the Sixth Circuit
• Decided: May 15, 2026
• Docket: 25-3272
• Status: Unpublished

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 26a0215n.06

No. 25-3272

UNITED STATES COURT OF APPEALS FILED May 15, 2026 FOR THE SIXTH CIRCUIT KELLY L. STEPHENS, Clerk ) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE ) NORTHERN DISTRICT OF LORENZO D. WATSON, ) OHIO Defendant-Appellant. ) ) OPINION )

Before: COLE, GRIFFIN, and READLER, Circuit Judges.

GRIFFIN, J., delivered the opinion of the court in which READLER, J., concurred. COLE, J. (pp. 7–8), delivered a separate opinion concurring in part and dissenting in part.

GRIFFIN, Circuit Judge.

While on federal supervised release, Lorenzo D. Watson was convicted in state court of

murder, attempted murder, and felonious assault. The district court sentenced him to 24 months’

imprisonment for these supervised release violations, set to run consecutive to his state sentences.

On appeal, Watson argues his sentence is procedurally and substantively unreasonable and violates

the Eighth Amendment. We disagree and affirm.

I.

In 2022, Watson pleaded guilty to possessing a firearm and ammunition as a felon. The

district court sentenced him to 16 months’ imprisonment followed by three years of supervised

release. No. 25-3272, United States v. Watson

Watson absconded while on supervised release and failed to maintain contact with his

probation officer. He also went on a violent crime spree. Watson was convicted in state court of

two counts of murder, two counts of felonious assault, and one count of attempted murder. For

his two murder convictions, Watson was sentenced to life in prison with the possibility of parole

after 30 years. His other state sentences for attempted murder and felonious assault were shorter,

and the state court ordered them all to run concurrently. So, in theory, Watson could be paroled

after serving a 30 year sentence for his state crimes.

In federal court, the only contested issue at the supervised release violation hearing was

whether Watson’s sentence would run concurrent or consecutive to his state sentences.

Considering Watson’s state sentences, his request for a concurrent sentence in federal court would

result in no extra prison time for his supervised release violations. The government argued that

Watson’s sentence should be consecutive to any state sentence due to “the absolutely despicable

and heinous nature of [Watson’s] conduct” while out on supervised release. The government

described how Watson shot one man in the back, a second in the stomach, a third in the face, and

how he nearly caved in a fourth man’s head.

As the district court imposed its sentence, it stressed that Watson’s murder spree took place

while the court was “responsible to the community for [him.]” The district court noted that, despite

its 26 years on the bench, no one else had committed murder while on supervised release, and it

explained that anything but a consecutive sentence would bring “disrespect” on the court. The

district court then imposed a consecutive sentence of 24 months’ imprisonment, which fell below

the Guidelines range but at the statutory maximum. Watson objected to the consecutive nature of

his sentence.

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After the hearing, the district court issued a written order, explaining that it imposed the

“sentence due to the violent nature of the offenses committed while on supervision.” Watson

appealed.

II.

Watson argues that his sentence is procedurally and substantively unreasonable. We

review challenges to the reasonableness of a sentence imposed after the revocation of supervised

release for an abuse of discretion. United States v. Morris, 71 F.4th 475, 480 (6th Cir. 2023).1

A.

To fashion a procedurally reasonable sentence, the district court must “properly calculate

the [G]uidelines range, treat that range as advisory, consider the sentencing factors in 18 U.S.C.

§ 3553(a), refrain from considering impermissible factors, select the sentence based on facts that

are not clearly erroneous, and adequately explain why it chose the sentence.” United States v.

Rayyan, 885 F.3d 436, 440 (6th Cir. 2018) (citing Gall v. United States, 552 U.S. 38, 51 (2007)).

A district court does not need to “engage in [a] ritualistic incantation” of the § 3553(a) factors, nor

must it “make specific findings relating to each of the factors considered.” United States v.

Washington, 147 F.3d 490, 490–91 (6th Cir. 1998) (citation modified). Moreover, a “within-the-

Guidelines sentence announced in a terse manner is not necessarily unreasonable.” United States

v. Glover, 167 F.4th 417, 429 (6th Cir. 2026). The “law leaves much . . . to the judge’s own

professional judgment,” especially when a matter is “conceptually simple.” Rita v. United States,

551 U.S. 338, 356, 359 (2007).

1 Watson and the government disagree on the applicable standard of review as to his procedural reasonableness challenge. Because the result would be the same under either standard, we review for abuse of discretion rather than plain error. United States v. Shabazz, 530 F. App’x 458, 463 (6th Cir. 2013). -3- No. 25-3272, United States v. Watson

Here, the “context and the record make clear” that the district court adequately considered

the relevant § 3553(a) factors. Id. at 359. The district court highlighted the fact that Watson’s

supervised release violations were heinous, remarking that despite more than a quarter-century on

the federal bench, no one else had “committed murder while on supervised release.” The district

court underscored the breach of trust by saying it “was responsible to the community” for Watson

during his crime spree. The district court added that any other sentence would bring “disrespect”

on the court. And its written order explains that the sentence was appropriate because of the

“violent nature of the offenses committed while on supervision.”

Between the sentencing transcript and the district court’s written order, the record is

sufficient to permit “reasonable appellate review.” United States v. Richardson, 437 F.3d 550,

554 (6th Cir. 2006) (citation modified) (“This assures not only that the defendant can understand

the basis for the particular sentence but also that the reviewing court can intelligently determine

whether the specific sentence is indeed reasonable.”). From all this, we can discern that the district

court weighed the relevant factors—namely, the circumstances of the violations, their seriousness,

and the need to protect the public. 18 U.S.C. § 3553(a)(1), (a)(2)(B)–(C). The district court was

well within its discretion to primarily rely on Watson’s brutal crime spree, and it made it “generally

clear” why it imposed a consecutive sentence. United States v. Johnson, 640 F.3d 195, 209

(6th Cir. 2011) (quoting United States v. Owens, 159 F.3d 221, 230 (6th Cir. 1998)). Watson’s

sentence is procedurally reasonable.

B.

A sentence is substantively unreasonable if it is “too long” or if the court placed “too much

weight on some of the § 3553(a) factors.” Rayyan, 885 F.3d at 442. But a sentence is not

substantively unreasonable simply because we “might reasonably have concluded that a different

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sentence was appropriate.” Gall, 552 U.S. at 51. We apply a rebuttable presumption that a within-

Guidelines sentence is reasonable. United States v. Vonner, 516 F.3d 382, 389–90 (6th Cir. 2008)

(en banc).

Watson argues his sentence is unreasonable because it “is greater than necessary to achieve

the goals of sentencing under § 3553(a),” and the district court “put too much weight on the need

to punish the new violation conduct.” But Watson offers no analogous authority for these

propositions. Watson asks us to conclude that a concurrent sentence may have been more

appropriate, but this “is insufficient to justify reversal.” Gall, 552 U.S. at 51.

Watson also argues that revocation of supervised release “is not meant to stack

punishment.” True, district courts “cannot consider § 3553(a)(2)(A) when revoking supervised

release.” Esteras v. United States, 606 U.S. 185, 195 (2025). Thus, they cannot consider “the

seriousness of the offense,” “respect for the law,” or “just punishment for the offense” when

imposing a sentence for a violation of supervised release. 18 U.S.C. § 3553(a)(2)(A). But the

court can consider an offender’s “breach of trust” while on supervised release, Esteras, 606 U.S.

at 194 n.5, as well as the “seriousness and nature of the supervised release conduct,” United States

v. Spence, 167 F.4th 882, 892 (6th Cir. 2026). And that is what the district court did here without

once referencing Watson’s original felon in possession offenses when sentencing him. As for the

nature of Watson’s supervised release violations, a murder spree is undoubtedly a serious breach

of trust, and the district court did not weigh it too heavily. See United States v. Patterson, 158 F.4th

700, 704 (6th Cir. 2025). So we discern no error on this front, either. Watson’s within-Guidelines

sentence is substantively reasonable.

III.

Watson avers that the district court violated the Eighth Amendment by imposing a

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consecutive sentence, which he argues removes his possibility of parole. We review a

constitutional challenge to a sentence de novo. United States v. Moore, 643 F.3d 451, 454 (6th

Cir. 2011).

The Eighth Amendment prohibits “cruel and unusual punishments.” U.S. Const. amend.

VIII. A sentence violates the Eighth Amendment when there is an “extreme disparity” between

the crime committed and the sentence imposed. Moore, 643 F.3d at 454 (quoting United States v.

Layne, 324 F.3d 464, 474 (6th Cir. 2003)). But we “grant substantial deference to the broad

authority that legislatures necessarily possess in determining the types and limits of punishments

for crimes, as well as to the discretion that trial courts possess in sentencing convicted criminals.”

Solem v. Helm, 463 U.S. 277, 290 (1983). And a “sentence within the statutory maximum set by

statute generally does not constitute cruel and unusual punishment.” Moore, 643 F.3d at 455

(citation modified).

The district court imposed a within-Guidelines sentence of 24 months’ imprisonment and

determined the sentence should run consecutive to Watson’s state sentence of life with the

possibility of parole. Given the egregious nature of Watson’s breach of trust while on supervised

release, his sentence does not pose an unconstitutional disparity.

IV.

For these reasons, we affirm the judgment of the district court.

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COLE, Circuit Judge, concurring in part and dissenting in part. I concur in the majority’s

analysis and conclusion that the district court did not violate Watson’s Eighth Amendment rights

by imposing a consecutive sentence. Because I believe the district court failed to consider the

applicable sentencing factors, however, I would vacate the district court’s sentence and remand

the case for resentencing. Thus, I respectfully dissent in part.

District courts maintain discretion in deciding whether to impose consecutive or concurrent

sentences. 18 U.S.C. § 3584(a). But “in making the determination, courts must consider the

§ 3553(a) factors . . . and must make generally clear the rationale under which it has imposed the

consecutive sentence.” United States v. Morris, 71 F.4th 475, 483 (6th Cir. 2023) (citation

modified). Although I agree with the majority opinion that the district court need not “engage in

a ritualistic incantation” of the § 3553(a) factors, see United States v. Washington, 147 F.3d 490,

491 (6th Cir. 1998) (citation modified), we must nonetheless find “‘sufficient evidence in the

record to affirmatively demonstrate the court’s consideration of’ the § 3553(a) factors.” United

States v. Thomas-Mathews, 81 F.4th 530, 545–46 (6th Cir. 2023) (quoting United States v.

McBride, 434 F.3d 470, 475 n.3 (6th Cir. 2006)). The record here lacks such evidence.

When sentencing Watson, the district court identified the Guidelines range of 24 months

and noted that it could run Watson’s sentence either consecutively or concurrently to his state

sentences. The court underscored that Watson committed his new offenses while the district court

“was responsible to the community for [his] behavior.” (Supervised Release Violation Hr’g Tr.,

R. 59, PageID 233; see also id. at 237, 239.) And the court said that it was “not sentencing now

. . . or considering sentencing Mr. Watson for [the violation] conduct.” (Id. at PageID 236.)

Although the district court properly acknowledged the sentences available to Watson and

considered the applicable Guidelines range, the record does not reflect that the court considered

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the remaining factors set forth in § 3553(a) such as Watson’s history and characteristics or the

need for adequate deterrence and protection of the public. The district court’s written order

reinforces my conclusion. In its written order, the district court explained that it “imposed the

sentence due to the violent nature of the offenses committed while on supervision.” (Mins. &

Order, R. 56, PageID 225.) It offered no further discussion of the § 3553(a) factors.

For its part, the government cites to its own statements during trial discussing Watson’s

“history of violence” and the need to “afford adequate deterrence and protect the public from future

crimes” as evidence that the district court considered the § 3553(a) factors. (Appellee Br. 17

(quoting Supervised Release Violation Hr’g Tr., R. 59, PageID 234–35).) The district court,

however, must explain the sentence it imposes, and it did not reference or adopt the government’s

statements. See United States v. Thomas, 498 F.3d 336, 340–41 (6th Cir. 2007) (explaining that a

district court cannot only note the parties’ arguments but must make clear its own reasoning on the

record). The government’s statements alone do not provide a sufficient explanation.

In my opinion, the district court abused its discretion by failing to discuss several of the

§ 3553(a) factors. I therefore conclude that Watson’s sentence is procedurally unreasonable and

would vacate his sentence and remand for resentencing.

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