United States v. Michael Williams

• Court: Court of Appeals for the Sixth Circuit
• Decided: April 1, 2026
• Docket: 25-5263
• Status: Unpublished

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 26a0154n.06

Case Nos. 25-5257/5263 FILED UNITED STATES COURT OF APPEALS Apr 01, 2026 FOR THE SIXTH CIRCUIT KELLY L. STEPHENS, Clerk

) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR ) THE EASTERN DISTRICT OF MICHAEL WILLIAMS, ) TENNESSEE ) Defendant-Appellant. ) OPINION )

Before: STRANCH, READLER, and BLOOMEKATZ, Circuit Judges.

PER CURIAM. Michael Williams violated the terms of his supervised release by

committing a new offense. In a single sentencing hearing, the district court revoked his supervised

release and imposed consecutive sentences on Williams for the new offense and the supervised

release violation. Williams challenges his resulting within-Guidelines sentence for the supervised

release violation as procedurally unreasonable, and he argues that the district court did not

adequately explain its reasons for imposing consecutive sentences. We disagree and affirm the

district court.

I.

Michael Williams has a history of run-ins with the law. Among his past offenses is a

federal drug trafficking conviction for possession with intent to distribute at least five grams of

crack cocaine. 21 U.S.C. § 841(a)(1), (b)(1)(B). His sentence for that offense included No. 25-5257/5263, United States v. Williams

incarceration and a six-year period of supervised release, a term that commenced in 2019 following

his release from prison under the First Step Act. One condition of Williams’s supervised release

was that he not commit another federal, state, or local crime while on supervision.

Unfortunately, Williams ultimately was unable to honor the conditions of his release. In

2024, officers received information that Williams had been distributing cocaine from his home.

After securing a warrant, officers searched the house. There, they discovered powder cocaine,

crack cocaine, digital scales, and baggies. Additionally, in a shed behind the home, officers found

approximately 300 grams of a cutting agent commonly used to increase the volume of drug

products. Following that discovery, Williams remarked to officers, “I’m screwed.” No. 25-5257,

R. 21, PageID 78–79. He then explained that he had been selling cocaine for about four months,

and that everything found during the search was “his responsibility.” Id. at 78–79.

A grand jury indicted Williams for possession with intent to distribute cocaine, in violation

of 21 U.S.C. § 841(a)(1), (b)(1)(B). Williams later pleaded guilty to a lesser included drug

trafficking offense under 21 U.S.C. § 841(a)(1), (b)(1)(C). During Williams’s ensuing sentencing

hearing, the district court sentenced Williams to 14-months’ imprisonment (within the

recommended Guidelines range of 8 to 14 months), plus three years of supervised release for this

new offense. The district court stated that it “imposed this sentence . . . to impress upon [Williams]

the necessity for respect for the law and to provide just punishment for the offense.”

Williams’s conduct, however, had further ramifications. His new conviction also

constituted a Grade A violation of his supervised release term tied to his previous drug trafficking

conviction, thereby requiring the district court to revoke Williams’s supervised release. U.S.

Sent’g Guidelines Manual § 7B1.3(a)(1) (U.S. Sent’g Comm’n 2023). The district court did so at

2 No. 25-5257/5263, United States v. Williams

the same time it sentenced Williams for his new charge, with the district court addressing the

sentence for the revocation and the new charge separately.

In announcing the revocation sentence, the district court considered several factors. It

explained that, “[w]hen someone is placed on supervised release,” the conditions are “tailored to

the defendant by the [c]ourt to help the defendant readjust to society so they can lead a law-abiding,

fruitful, and productive life.” Id. at PageID 342. The court noted that, “[w]hen a defendant does

not comply with the terms and conditions, then that lets the courts down,” and “it violates the trust

the [c]ourt placed in the person,” which requires the court “to take some action to impress upon

the defendant the necessity of obeying the Court’s order.” Id. The court also noted that Williams

has a “long history of criminal violations.” No. 25-5257, R. 36, PageID 346. Those realities, the

court explained, made it imperative to “impress upon [Williams] the necessity of obeying all the

terms of his supervised release, not violating the law while he’s on supervised release, and doing

all that he can to make sure that he becomes [a] law-abiding and productive citizen” going forward.

Id. at PageID 347. The court remarked that “more” “deterrence” and “respect for the law” “are

needed in this case with respect to Mr. Williams.” Id. at PageID 343. And the court stated that a

within-Guidelines revocation sentence was “necessary to reach all of the [§] 3553 goals.” Id. In

the end, the court sentenced Williams to 51-months’ imprisonment for violating his previous

supervised release terms, to be served consecutively to his sentence for his most recent trafficking

conviction. Critical to the court’s determination to make the sentences consecutive (rather than

concurrent) was “the recommendation of the Sentencing Commission in cases such as this” and

the “need for [Williams] to understand the importance of him complying with the law,” and to

“demonstrate to [Williams] that there is a separate harm that was caused above and beyond the

new crime, and that’s the violation of the trust that the [c]ourt placed in him.” Id. at 348.

3 No. 25-5257/5263, United States v. Williams

II.

On appeal, Williams asserts that the revocation of his supervised release was the product

of two procedural errors. Cf. 18 U.S.C. § 3583(e) (setting out factors that govern supervised

release). One, the district court improperly considered retributive factors in revoking Williams’s

supervised release, in violation of Esteras v. United States, 145 S. Ct. 2031 (2025). And two, the

court failed to provide proper justifications for why it made Williams’s sentence for his new drug

trafficking conviction run consecutively to the revocation sentence.

For a sentence to be procedurally reasonable, the district court must properly calculate the

Guidelines range, treat the range as advisory, consider the permissible 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); see also United States v. Adams, 124 F.4th

432, 438 (6th Cir. 2024) (applying these criteria to a revocation of supervised release sentence).

The parties agree that we review this issue for an abuse of discretion. See Adams, 124 F.4th at

438; United States v. King, 914 F.3d 1021, 1024 (6th Cir. 2019). To that end, a district court

abuses its discretion if it selects “a sentence based on clearly erroneous facts[] or fail[s] to

adequately explain the chosen sentence—including an explanation for any deviation from the

Guidelines range.” Gall v. United States, 552 U.S. 38, 51 (2007).

A.1. Section 3583(e) provides that a court may revoke a defendant’s supervised release

“after considering the factors set forth in section 3553(a)(1), (a)(2)(B), (a)(2)(D), (a)(4), (a)(5),

(a)(6), and (a)(7).” 18 U.S.C. § 3583(e). Absent from this list is § 3553(a)(2)(A), which directs

courts to consider “the need for the sentence imposed” “to reflect the seriousness of the offense,

to promote respect for the law, and to provide just punishment for the offense.” Id.

4 No. 25-5257/5263, United States v. Williams

§ 3553(a)(2)(A). In Esteras, the Supreme Court held that a district court, as part of a supervised

release revocation hearing, may not consider the “seriousness of the [defendant’s original

underlying] offense” when imposing a sentence for the supervised release violation because the

supervised release statute did not incorporate that § 3553(a) factor. See 145 S. Ct. at 2040

(emphasizing that 18 U.S.C. § 3553(a)(2)(A)—which lists retributive factors of “seriousness of

the offense”, “respect for the law”, and “just punishment for the offense”—is absent in the factors

delineated in § 3583(e), the statute governing supervised release). The Court explained that,

“when a defendant violates the conditions of his supervised release, it makes sense that a court

must consider the forward-looking ends of sentencing (deterrence, incapacitation, and

rehabilitation), but may not consider the backward-looking purpose of retribution.” Id. at 2031.

Against this backdrop, Williams does not argue that the district court violated Esteras by

sentencing him to punish his original offense. Instead, Williams argues for an extension of Esteras,

asserting that because supervised release is designed to be forward looking and rehabilitative, any

retributive consideration in setting a sentence for a supervised release violation, however framed,

is off limits. In so doing, Williams acknowledges that Esteras expressly left open whether 18

U.S.C. § 3583(e) permits a district court to sanction a defendant for failing to obey court-ordered

conditions of supervised release as the Guidelines recommend. See Appellant Br. at 21 (“But

[Esteras] left another question open—can a court impose retribution for the violation itself?”); see

also 145 S. Ct. at 2040 n.5 (“We take no position on whether” “‘sanction[ing] the violator for

failing to abide by the conditions of the court-ordered supervision’” “is a permissible

consideration.” (quoting U.S. Sent’g Guidelines Manual ch. 7, pt. A, introductory cmt. 3(b) (U.S.

Sent’g Comm’n 2024))).

5 No. 25-5257/5263, United States v. Williams

Williams’s position is in tension with our post-Esteras precedent. We have held that the

breach of trust rationale, which sometimes may sound in backward looking, retributive

considerations, is fair game. United States v. Patterson, 158 F.4th 700, 702 n.2 (6th Cir. 2025)

(“[Defendant] still insists that Esteras’s logic implies that courts can’t consider any retributive

consideration . . . . We disagree.”); see also United States v. Lopez, No. 25-1644-cr, 2026 WL

112352, at *2 (2d Cir. Jan. 15, 2026) (mem.) (“[T]he district court’s consideration of the

seriousness of Lopez’s violations, and reliance on its determination that it was obvious here that

the breach of the Court’s trust was extreme, was permissible under the Guidelines and our

precedent, which was left undisturbed by Esteras.” (citation modified)). The same is true of a

district court’s consideration of the seriousness of the supervised release violation conduct, which

Williams claims is barred by § 3583(e). A sentencing court may consider the seriousness of a

supervised release violation to the extent that it informs permissible considerations such as

deterrence, protection of the public, and rehabilitation. United States v. Sims, 161 F.4th 455, 459

(6th Cir. 2025); United States v. Welch, No. 25-5136, 2026 WL 209787, at *2 (6th Cir. Jan. 27,

2026); United States v. Spence, 167 F.4th 882, 892 (6th Cir. 2026); United States v. Simpson, No.

23-3961, 2025 U.S. App. LEXIS 19442, at *3 (6th Cir. July 31, 2025) (mem.); see also United

States v. Panezo Tenorio, No. 24-13143, 2025 WL 2305475, at *1 (11th Cir. Aug. 11, 2025) (after

Esteras, a district court may “take into account the seriousness of their violation of the conditions

of their supervised release”). “[N]othing in [Esteras],” in other words, “prohibit[s] a district court

from considering the seriousness of the supervised-release violation” itself. Sims, 161 F.4th at 459

(citing Patterson, 158 F.4th at 702).

Williams takes issue with this conclusion, in particular our reliance on Patterson.

Specifically, he faults Patterson for “treat[ing] Esteras’s silence on violation conduct as

6 No. 25-5257/5263, United States v. Williams

dispositive,” and believes we thus erred there by not “asking whether Esteras’s text-and-structure

analysis abrogated” our pre-Esteras decisions that allowed a sentencing court to consider the

violation’s seriousness when imposing a sentence for the breach of trust caused by that violation.

But whether we agree with Patterson and similar cases, as a subsequent panel we have no license

to second guess their conclusions. See Sykes v. Anderson, 625 F.3d 294, 319 (6th Cir. 2010) (“[A]

published prior panel decision remains controlling authority unless an inconsistent decision of the

United States Supreme Court requires modification of the decision or this Court sitting en banc

overrules the prior decision.” (citation modified)); see also United States v. Ferguson, 868 F.3d

514, 515 (6th Cir. 2017) (noting our longstanding rule that one panel may not overrule the decision

of another).

A.2. Even if we thought our precedent left the door open for Williams’s argument that

Esteras bars all considerations of retribution, his challenge would still fall short, because we do

not read the district court as relying on retributive purposes when imposing Williams’s revocation

sentence. As a starting point, we presume that district courts understand and apply governing law,

and we do not manufacture procedural error from sentencing remarks that, read in context, reflect

reliance on proper factors. See United States v. Vonner, 516 F.3d 382, 392 (6th Cir. 2008) (en

banc); Spence, 167 F.4th at 891–92. Here, we are assured that the district court grounded its

revocation decision in permissible, forward-looking considerations, not any impermissible

“backward-looking” purpose. Esteras, 145 S. Ct. at 2041; see id. at 2043–44.

The district court repeatedly framed its explanation for Williams’s supervised release

violation sentence in forward looking terms related to deterrence, a permissible factor under

§ 3553(a)(2)(B). See Patterson, 158 F.4th at 704. It began by emphasizing that the

“consideration[s]” for a sentence tied to the revocation of supervised release are “very different”

7 No. 25-5257/5263, United States v. Williams

from the sentencing considerations that undergird sentencing for an initial offense. No. 25-5257,

R. 36, PageID 342. Speaking to the revocation context, the court described the relevant

considerations in rehabilitative terms, explaining that supervised release is intended to “help the

defendant readjust to society so they can lead a law-abiding, fruitful, and productive life.” Id.; see

United States v. Williams, 739 F.3d 1064, 1065 (7th Cir. 2014) (noting that descriptions about a

defendant’s transition to community life are rehabilitative). Next, after finding that Williams had

violated the terms of his supervised release, the district court reiterated that, in considering an

appropriate sentence, the court intends for “defendants [to do] well on supervised release so they

will be productive and law-abiding citizens.” No. 25-5257, R. 36, PageID 346. This emphasis on

the forward looking, rehabilitative purpose of supervised release assures us that the district court

did not rely on retributive factors when sentencing Williams.

Equally telling is what the district court did not say. See Welch, 2026 WL 209787, at *3.

Namely, it made no reference to concepts like “just punishment” or the “seriousness of the

offense,” notions that may suggest a retributive rationale. See, e.g., Esteras, 145 S. Ct. at 2043.

At no point during the revocation hearing did the court emphasize the need to punish Williams.

Indeed, the district court expressly segregated its views on the appropriate sentence for revocation

from the sentence for the new charge, understanding the considerations for each to differ. Cf.

United States v. Hoyle, 148 F.4th 396, 406 (6th Cir. 2025) (vacating a sentence where the district

court’s explanation blurred its punishment rationale for the underlying offense with its assessment

of the supervised release violation). This reality cements the conclusion that the district court

committed no procedural error under Esteras.

Williams is correct to note that a sentencing court’s reference to “respecting the law can

signify, under some circumstances, consideration of the retribution and punishment disallowed

8 No. 25-5257/5263, United States v. Williams

under Esteras.” United States v. Milton, Nos. 24-4066/4067, 2025 WL 2965822, at *6 (6th Cir.

Oct. 21, 2025). But a sentencing court’s emphasis on following the law may also signify

consideration of deterrence goals. See United States v. Martin, 109 F.4th 985, 990 (7th Cir. 2024)

(promoting respect for the law “is a way to deter further criminal conduct”). Here, the district

court’s brief reference to “respect for the law” in the context of Williams’s revocation sentence is

a stray comment that even when viewed in the most jaundiced manner cannot justify reversal. See

Esteras, 145 S. Ct. at 2045 (suggesting that a “stray reference to a § 3553(a)(2)(A) factor” is not

reversible error where the reference “was intended to bear on another § 3553(a) factor or merely

prefatory”); see also United States v. Hymes, 19 F.4th 928, 934 (6th Cir. 2021) (“[O]ne stray

comment at sentencing cannot establish a reversible sentencing error.”). Read in context, the

comment is better understood as a consideration of deterrence alone. After detailing Williams’s

“long history of criminal violations,” No. 25-5257, R. 36, PageID 346, the district court explained

that it intended to “impress upon [Williams] the necessity of obeying all the terms of his supervised

release, not violating the law while he’s on supervised release, and doing all that he can to make

sure that he becomes the law-abiding and productive citizen that the Court wishes him to be,” id.

at PageID 346–47. In other words, the district court hoped Williams’s sentence tied to his

revocation of supervised release would help him “understand the importance of him complying

with the law,” thereby deterring him from committing future crimes. Id. at PageID 348. The goal

of transforming Williams into a future law-abiding citizen sounds in deterrence, not retribution.

See United States v. Weaver, 920 F.2d 1570, 1576 (11th Cir. 1991) (explaining that, in determining

a sentence sufficient to deter future criminal conduct, a court should consider the defendant’s

criminal history to assess the likelihood of recidivism); Esteras, 145 S. Ct. at 2041.

9 No. 25-5257/5263, United States v. Williams

Resisting this conclusion, Williams highlights the district court’s reference to “all of the

[§] 3553 goals,” its statement that it needed to “impress upon” Williams the importance of

compliance, and its repeated emphasis on “obeying” court orders and the terms of supervised

release. No. 25-5257, R. 36, PageID 343, 346–47. Relatedly, he portrays the court’s recurring

references to a “violation of the trust” as reflecting a retributive purpose. See, e.g., id. at PageID

348.

Read in context, however, none of these statements support Williams’s characterization.

The district court explicitly tied its concern about compliance and respect for court orders to

forward looking aims, not to punishment for past conduct. See id. at PageID 346–47 (explaining

that, absent a sentence sufficient to deter further violations, Williams was unlikely to become a

“law-abiding and productive citizen”). The court’s effort to “impress upon” Williams the

importance of obeying the law reflects a concern for future compliance, not retribution for failing

to do so in the past. See Esteras, 145 S. Ct. at 2043 (explaining that courts may consider past

conduct insofar as it informs deterrence, public protection, or rehabilitation).

Nor does the district court’s passing reference to “all of the [§] 3553 goals” alter our

conclusion. No. 25-5257, R. 36, PageID 343. When determining whether the district court

“relied” on retributive factors, see Esteras, 145 S. Ct. at 2045, we consider the record as a whole.

See United States v. Johnson, No. 24-3787, 2026 WL 50666, at *3 (6th Cir. Jan. 7, 2026) (no

procedural error where the district court mentioned that the supervised-release violation required

a “serious sanction” and the defendant’s history of violent crime). In one sense, the district court’s

statement that Williams needed more “deterrence, respect for the law, and specific deterrence”

could be understood to include the goal of retribution. No. 25-5257, R. 36, PageID 343. But we

take the district court to have made this observation with respect to Williams’s respect for court

10 No. 25-5257/5263, United States v. Williams

ordered conditions of supervised release not the underlying offense. After all, the district court

did not mention retributive concepts such as just punishment or seriousness of the offense when

explaining its sentence for the supervised release violation. In the end, a passing reference to the

§ 3553(a) factors and respect for the law, without more, does not imply that the district court

“actually relied on § 3553(a)(2)(A).” Esteras, 145 S. Ct. at 2045.

Williams similarly misses the mark by focusing on the district court’s references to a

“breach of trust.” To begin, the district court—as with its other statements emphasized by

Williams here—invoked breach of trust to explain why prior supervision had failed, and why a

more substantial sanction was necessary to deter further violations and rehabilitate Williams, not

to impose punishment for punishment’s sake. See No. 25-5257, R. 36, PageID 346–48. Chapter

Seven of the Guidelines Manual includes a policy statement that instructs courts to “sanction

primarily the defendant’s breach of trust” when fashioning all revocation sentences. U.S. Sent’g

Guidelines Manual ch. 7, pt. A, introductory cmt. (3)(b) (U.S. Sent’g Comm’n 2023). In doing so,

the Commission frames the breach of trust rationale in contrast to punishment. See id. Although

the Policy Statements are advisory and “not binding” on a district court, the court must at least

“consider” them prior to imposing a sentence for revocation of supervised release. See United

States v. Johnson, 640 F.3d 195, 208 (6th Cir. 2011) (explaining that although not binding, district

courts “must consider § 7B1.3(f) when it is applicable”).

In line with this guidance and as already explained, our precedent permits district courts to

sanction the breach of trust associated with a violation of supervised release. See id. at 203; United

States v. Morris, 71 F.4th 475, 482 (6th Cir. 2023). Esteras did not change that. United States

v. Hunter, No. 25-3069, 2025 WL 3731056, at *2–3 (6th Cir. Dec. 26, 2025) (citing Morris, 71

F.4th at 482) (explaining that district courts may continue to consider the breach of trust rationale

11 No. 25-5257/5263, United States v. Williams

because Esteras reserved the question and therefore does not abrogate our precedent allowing

district courts to sanction a defendant’s breach of the court’s trust). What is more, other circuit

courts to consider the issue after Esteras have not reversed a district court for treating supervised

release violations as a breach of trust. See, e.g., United States v. Benton, Nos. 24-4029/4030, 2025

WL 2389423, at *4 n.2 (4th Cir. Aug. 18, 2025); United States v. Butler, No. 25-12027, 2025 WL

2642292, at *3 (11th Cir. Sep. 15, 2025) (per curiam). In the end, taking account of both this

authority and the district court’s deterrent and rehabilitative framing of the breach of trust caused

by the supervised release violation, we see no basis to conclude that the district court procedurally

erred by considering an impermissible factor in fashioning Williams’s revocation sentence.

B. Turn now to Williams’s assertion that the district court failed to sufficiently explain its

decision to impose consecutive sentences for his new conviction along with his revocation

violation. In general, district courts enjoy discretion in assessing whether to impose consecutive

or concurrent sentences. King, 914 F.3d at 1024–25. Should it choose to enter a consecutive

sentence, the district court must account for the applicable § 3553(a) factors and applicable

Guidelines and policy statements, though these advisements are not binding on the district court.

Johnson, 640 F.3d at 208. And if the court ultimately decides to impose a consecutive sentence,

it “‘generally [must make] clear the rationale under which it has’” done so. King, 914 F.3d at 1025

(quoting United States v. Hall, 632 F.3d 331, 335 (6th Cir. 2011)). With respect to the supervised

release setting in particular, at the time of Williams’s sentencing, the Guidelines recommended

that “[a]ny term of imprisonment imposed upon the revocation of . . . supervised release shall be

ordered to be served consecutively to any sentence of imprisonment that the defendant is serving,

whether or not the sentence of imprisonment being served resulted from the conduct that is the

12 No. 25-5257/5263, United States v. Williams

basis of the revocation of . . . supervised release.” U.S. Sent’g Guidelines Manual § 7B1.3(f) (U.S.

Sent’g Comm’n 2023) (titled “Revocation of Probation or Supervised Release”).

Here, the district court plainly explained its rationale for ordering the sentence tied to the

new drug trafficking conviction to run consecutively to the revocation sentence. Again, the

Sentencing Commission’s recommendation for defendants like Williams is that the revocation

sentence shall run consecutively to any new sentence. See id. The district court explained that it

agreed with that recommendation. As the district court put it, Williams’s conduct caused two

“separate harm[s]”: His new criminal offense violated the law, and his breach of the terms of his

supervised release “violat[ed] the trust that the [c]ourt’s placed in him.” No. 25-5257, R. 36,

PageID 348; see United States v. Lester, 98 F.4th 768, 779 (6th Cir. 2024). Williams’s supervised

release violation, in other words, caused a “separate harm . . . above and beyond the new crime,

and that’s the violation of the trust that the [c]ourt placed in him.” No. 25-5257, R. 36,

PageID 348. In the end, his “significant and repeated breaches of the court’s trust more than

justified its decision to impose a consecutive sentence.” United States v. Hinojosa, 67 F.4th 334,

347 (6th Cir. 2023).

Williams disagrees in multiple respects. He first contends that the then applicable

§ 7B1.3(f) provision applies only when the defendant is “already serving another sentence at the

time of revocation.” Appellant Br. That portrayal cuts too fine a distinction. As our cases reflect,

we frequently interpret § 7B1.3(f) to allow a district court to impose sentences for new convictions

and revocation sentences in the same hearing. See, e.g., United States v. Sears, 32 F.4th 569, 572,

576 (6th Cir. 2022); King, 914 F.3d at 1024–25; Milton, 2025 WL 2965822, at *2, *4. Indeed,

even Williams ultimately acknowledges that imposing consecutive sentences is in line with the

current Sentencing Guidelines instructions.

13 No. 25-5257/5263, United States v. Williams

Second, Williams asserts that the district court should have taken notice of proposed

amendments to the Sentencing Guidelines regarding consecutive sentences. Those proposals,

which were adopted several months after Williams’s sentencing, recommended different language

for probation and supervised release. The Sentencing Guidelines now instruct that “[a]ny term of

imprisonment imposed upon the revocation of probation shall be ordered to be served

consecutively to any sentence of imprisonment that the defendant is serving,” U.S. Sent’g

Guidelines Manual § 7B1.3(a)(1) (U.S. Sent’g Comm’n 2025) (emphasis added), but “[a]ny term

of imprisonment imposed upon the revocation of supervised release generally should be ordered

to be served consecutively to any sentence of imprisonment that the defendant is serving.” Id.

§ 7C1.4(b) (emphasis added).

Multiple flaws plague his contention. To begin, Williams never asked the court to consider

those amendments, and the court understandably “was not obligated to consider [a proposed

amendment] sua sponte.” United States v. Jimenez, 517 F. App’x 398, 400 (6th Cir. 2013) (per

curiam). And even had Williams done so, “a district court applies the version of the Guidelines in

effect at the time of sentencing,” not as they might later be amended. Huff v. United States, 734

F.3d 600, 608 (6th Cir. 2013); see also United States v. Simpson, 138 F.4th 438, 455 (6th Cir.

2025). Add to all of this that, as Williams admits, the Guidelines still recommend consecutive

sentences in situations like Williams’s—meaning the Guidelines shift from mandatory language

to a recommendation likely would not have meaningfully altered the district court’s analysis.

Lastly, Williams returns to questioning the district court’s breach of trust rationale. Yet

that rationale was proper as to the imposition of consecutive sentences for the same reasons it was

appropriate in informing his sentence arising from his supervised release violation. In neither

instance did the district court appear to be imposing the sentence for punishment’s sake, and, even

14 No. 25-5257/5263, United States v. Williams

so, it is permitted to invoke punitive principles for the new violation, just not for the underlying

criminal conviction. See Patterson, 158 F.4th at 702; Sims, 161 F.4th at 459.

* * * * *

We affirm.