United States v. Matthew Brown

CourtCourt of Appeals for the Sixth Circuit
DecidedJanuary 22, 2025
Docket24-3232
StatusUnpublished

This text of United States v. Matthew Brown (United States v. Matthew Brown) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Matthew Brown, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0028n.06

No. 24-3232

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Jan 22, 2025 KELLY L. STEPHENS, Clerk ) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE UNITED ) STATES DISTRICT COURT FOR v. ) THE NORTHERN DISTRICT OF ) OHIO MATTHEW J. BROWN, ) Defendant-Appellant. ) OPINION

Before: GILMAN, STRANCH, and LARSEN, Circuit Judges.

RONALD LEE GILMAN, Circuit Judge. Matthew J. Brown pleaded guilty, without a

plea agreement, to one count of being a felon in possession of a firearm. He appeals his sentence

of 78 months of imprisonment, arguing that his sentence is substantively unreasonable. For the

reasons set forth below, we AFFIRM the judgment of the district court.

I. BACKGROUND

On December 17, 2022, police found Brown, his son, and another companion with an open

container of alcohol in a car parked at a gas station. They arrested Brown when they discovered a

stolen firearm in one of his coat pockets. At the time, Brown was on post-release supervision for

a state sexual-battery conviction.

Brown pleaded guilty to one count of violating 18 U.S.C. § 922(g)(1) and

18 U.S.C. § 924(a)(8) by being a felon in possession of a firearm. In its Presentence Report, the No. 24-3232, United States v. Brown

Probation Department recommended a base offense level of 20. It then added a two-point

enhancement for Brown’s possession of the stolen firearm, but also applied a three-level reduction

for his acceptance of responsibility. The net total offense level was thus set at 19. After reviewing

Brown’s extensive criminal history, the Probation Department next recommended a criminal-

history category of VI. This resulted in an applicable Guidelines range of 63 to 78 months of

imprisonment. The Probation Department finally noted that a downward variance might be

appropriate because of Brown’s personal history and characteristics.

Brown was sentenced in March 2024. The district court began the sentencing hearing by

describing Brown’s offense conduct, reviewing the Presentence Report, and identifying the

uncontested Guidelines range of 63 to 78 months of imprisonment. Both parties then discussed

the 18 U.S.C. § 3553(a) factors. The government emphasized Brown’s long criminal history and

noted that Brown had not previously received any sentence longer than his most recent sentence

of 60 months for sexual battery.

Because Brown’s past sentences had not deterred him from future criminal activity, the

government asked the district court to sentence Brown to 78 months of imprisonment, at the high

end of the applicable Guidelines range. Defense counsel, on the other hand, argued that Brown

was seeking to improve himself, had accepted responsibility for his actions, and had strong family

and community ties. His counsel then requested that the court sentence Brown to 63 months of

imprisonment, which was at the low end of the applicable Guidelines range. This low-end

sentence, according to available sentencing data, was also the median sentence for defendants

found guilty of similar conduct.

After hearing argument from both sides, the district court applied the § 3553(a) factors.

The court noted that Brown had refused to comply with the arresting officer’s commands, had

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begun reaching for his coat pocket containing the loaded, stolen firearm, and was in the vehicle

with two others. One of those in the car with Brown was his adult son, who was in possession of

his own loaded firearm. The court also noted that Brown had an extensive criminal history that

included drug possession, drug trafficking, the unlawful possession of weapons, receipt of stolen

property, possession of criminal tools, promotion of prostitution, juvenile rape, and sexual battery.

But as mitigating factors, the court acknowledged Brown’s unstable upbringing, periods of

homelessness, substance abuse, favorable employment history, and his relationship with his 14

children.

The district court ultimately reasoned that no previous term of confinement, including the

recent term of 60 months of imprisonment for sexual battery, had deterred Brown from additional

criminal conduct. With this and the other § 3553(a) factors in mind, the court stated that a sentence

of 63 months was insufficient because it was only 3 months more than the 60-month sexual-battery

sentence. It also noted that Brown had violated his post-release supervision for that sentence by

possessing the firearm in question. The court concluded by sentencing Brown to 78 months of

imprisonment. Defense counsel objected to the “high-end sentence.” This timely appeal followed.

II. ANALYSIS

On appeal, Brown argues that his sentence is substantively unreasonable because it is

greater than necessary to achieve the goals of sentencing pursuant to 18 U.S.C. § 3553(a). He

argues that the district court did not appropriately weigh mitigating factors like Brown’s

acceptance of responsibility for his offense, the fact that his unlawful possession of the firearm

was the sole offense, and his difficult family background. Brown also contends that the court

improperly relied on his prior 60-month sentence for sexual battery and used it as a benchmark.

-3- No. 24-3232, United States v. Brown

When we review a defendant’s sentence for substantive reasonableness, we generally apply

the abuse-of-discretion standard. See Gall v. United States, 552 U.S. 38, 51 (2007). “A district

court abuses its discretion when it applies the incorrect legal standard, misapplies the correct legal

standard, or relies upon clearly erroneous findings of fact.” United States v. Pugh, 405 F.3d 390,

397 (6th Cir. 2005) (quoting Schenck v. City of Hudson, 114 F.3d 590, 593 (6th Cir. 1997)).

“A sentence may be considered substantively unreasonable when the district court . . . gives

an unreasonable amount of weight to any pertinent factor” under 18 U.S.C. § 3553(a). United

States v. Conatser, 514 F.3d 508, 520 (6th Cir. 2008). The § 3553(a) factors, which the court must

consider, include “the nature and circumstances of the offense,” “the history and characteristics of

the defendant,” and the need for the sentence “to reflect the seriousness of the offense,” “promote

respect for the law,” “provide just punishment,” “afford adequate deterrence to criminal conduct,”

and “protect the public.” 18 U.S.C. § 3553(a). “In reviewing for substantive reasonableness, we

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Related

Gall v. United States
552 U.S. 38 (Supreme Court, 2007)
Mark Schenck v. The City of Hudson
114 F.3d 590 (Sixth Circuit, 1997)
United States v. Bolds
511 F.3d 568 (Sixth Circuit, 2007)
United States v. Conatser
514 F.3d 508 (Sixth Circuit, 2008)

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