United States v. Matthew Thomas

CourtCourt of Appeals for the Sixth Circuit
DecidedJune 4, 2025
Docket24-5063
StatusUnpublished

This text of United States v. Matthew Thomas (United States v. Matthew Thomas) 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 Thomas, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0272n.06

No. 24-5063

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Jun 04, 2025 KELLY L. STEPHENS, Clerk ) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE EASTERN ) DISTRICT OF KENTUCKY MATTHEW THOMAS, ) Defendant-Appellant. ) OPINION ) )

Before: MOORE, BUSH, and NALBANDIAN, Circuit Judges.

KAREN NELSON MOORE, Circuit Judge. Matthew Thomas, a federal prisoner, was

sentenced to 114 months of imprisonment for possession of a firearm by a convicted felon in

violation of 18 U.S.C. § 922(g)(1). This sentence is nearly one and a half times the top end of

Thomas’s 63- to 78-month guidelines range. Thomas challenges the substantive reasonableness

of this upward variance. Because the district court adequately explained why an upward variance

was warranted, we hold that the district court did not abuse its discretion. Accordingly, we

AFFIRM.

I. BACKGROUND

On May 18, 2021, Thomas was arrested for possessing a stolen handgun. R. 72 (PSR ¶¶ 7–

10) (Page ID #221–22). He had stolen the firearm from his mother. Id. Thomas “had been seen

waving a gun around and acting very manic before leaving his girlfriend’s house.” Id. ¶ 9 (Page No. 24-5063, United States v. Thomas

ID #222). After local police confronted Thomas, he admitted to possessing the weapon and

complied with their instructions. Id. ¶ 10 (Page ID #222).

On August 25, 2022, a grand jury indicted Thomas on two counts—one under 18 U.S.C.

§ 922(g)(1) and the other under § 922(j). R. 1 (Indictment at 1) (Page ID #1). On October 27,

2022, the Government filed a superseding indictment, charging the same two counts, but adding

additional allegations asserting that Thomas was eligible for an enhanced penalty under the Armed

Career Criminal Act (ACCA), 18 U.S.C. § 924(e). R. 17 (Superseding Indictment at 1–2) (Page

ID #37–38). Following an assessment of his competency, Thomas stipulated to a psychological

evaluation that he suffers from: “(1) Schizotypal Personality Disorder, (2) Alcohol Use Disorder,

severe, in a controlled environment, and (3) Stimulant Use Disorder (methamphetamine), severe,

in a controlled environment.” R. 48 (Order Adopting Competency Finding at 2–3) (Page ID #111–

12).

Thomas pleaded guilty on July 25, 2023, to the § 922(g)(1) count. R. 81 (Re-Arraignment

Tr. at 28) (Page ID #357). At the January 9, 2024 sentencing, and although the Government argued

that the district court should apply the ACCA sentencing enhancement, the district court found

that Thomas’s prior convictions did not qualify as predicate offenses. R. 79 (Sent’g Tr. at 24–38)

(Page ID #279–93). Consequently, Thomas’s guideline range decreased from 180- to 210-months

of imprisonment, R. 72 (PSR ¶ 73) (Page ID #237), to 63- to 78-months of imprisonment, R. 79

(Sent’g Tr. at 42) (Page ID #297). The district court adopted the government’s specific

recommendation, and sentenced Thomas to 114 months of imprisonment to run concurrent with a

related state-court matter. Id. at 46, 58–60 (Page ID #301, 313–15).

2 No. 24-5063, United States v. Thomas

In varying upward from Thomas’s guidelines range, the district court principally noted his

violent criminal history. Id. at 52, 57–58 (Page ID #307, 312–13) This history included Thomas’s

three convictions for sexual assault, one of which involved a minor under twelve-years-old. Id. at

53 (Page ID #308). Thomas also had a history of resisting arrest and fleeing the police, often

armed with a knife. Id. at 53–54 (Page ID #308–09). Based on Thomas’s lengthy criminal history,

the district court determined that his prior five-year sentences had not deterred him, and that his

current sentence would have to be sufficient to deter him from future criminal conduct. Id. at 54

(Page ID #309).

Although the district court noted that “there may be some small mitigating factors related

to [Thomas’s] mental health,” those mitigating factors were outweighed by “a really aggravating

factor involving [his] criminal history.” Id. at 53 (Page ID #308). In declining to sentence Thomas

within the guideline range, the district court noted the need for specific deterrence, that Thomas

did not receive the ACCA sentencing enhancement despite his violent criminal history, and his

“violent recidivist, persistent and troubling criminal history.” Id. at 57 (Page ID #312). Thomas’s

114-month sentence “is about a 45 percent upward variance from the high end of the guideline

range.” Id. at 58 (Page ID #313).

II. STANDARD OF REVIEW

Thomas challenges the substantive reasonableness of his above-guidelines sentence. We

review the substantive reasonableness of a sentence under the abuse-of-discretion standard. See

Gall v. United States, 552 U.S. 38, 41 (2007).

3 No. 24-5063, United States v. Thomas

III. ANALYSIS

Thomas challenges only the district court’s reliance on his extensive criminal history in

varying upward. Because the district court adequately explained why an upward variance was

warranted in these circumstances, we affirm.

“Substantive reasonableness focuses on whether a sentence is too long (if a defendant

appeals) or too short (if the government appeals).” United States v. Mitchell, 107 F.4th 534, 544

(6th Cir. 2024) (quoting United States v. Parrish, 915 F.3d 1043, 1047 (6th Cir. 2019)). The

question is whether “the court placed too much weight on some of the [sentencing] factors and too

little on others in sentencing the individual.” Id. (quoting United States v. Rayyan, 885 F.3d 436,

442 (6th Cir. 2018)). “If the court failed to give ‘reasonable weight to each relevant factor,’ the

sentence that results is substantively unreasonable.” United States v. Perez-Rodriguez, 960 F.3d

748, 754 (6th Cir. 2020) (quoting United States v. Boucher, 937 F.3d 702, 707 (6th Cir. 2019)).

“[A] sentence above the guidelines range ‘requires the district court to consider the extent

of the deviation to ensure that the justification is sufficiently compelling to support the degree of

variance.’” United States v. Johnson, 26 F.4th 726, 736 (6th Cir. 2022) (quoting Perez-Rodriguez,

960 F.3d at 754). “In doing so, the district court must explain ‘how the present case is different

from the typical or mine-run case’ within the ‘heartland to which the Commission intends

individual Guidelines to apply.’” Id. (quoting Perez-Rodriguez, 960 F.3d at 754). “Relevant here,

‘[t]he greater the variance, the more compelling the justification must be.’” Id. (alteration in

original) (quoting Perez-Rodriguez, 960 F.3d at 754). “And when a sentence ‘departs from the

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Related

Gall v. United States
552 U.S. 38 (Supreme Court, 2007)
United States v. Khalil Abu Rayyan
885 F.3d 436 (Sixth Circuit, 2018)
United States v. Richard Parrish
915 F.3d 1043 (Sixth Circuit, 2019)
United States v. Rene Boucher
937 F.3d 702 (Sixth Circuit, 2019)
United States v. Eduardo Perez-Rodriguez
960 F.3d 748 (Sixth Circuit, 2020)
United States v. Michael Johnson, II
26 F.4th 726 (Sixth Circuit, 2022)
United States v. O'Bryan Mitchell
107 F.4th 534 (Sixth Circuit, 2024)

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