United States v. Patrick Howard Brady

CourtCourt of Appeals for the Sixth Circuit
DecidedMay 19, 2025
Docket24-5940
StatusUnpublished

This text of United States v. Patrick Howard Brady (United States v. Patrick Howard Brady) 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. Patrick Howard Brady, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0255n.06

No. 24-5940

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED May 19, 2025 UNITED STATES OF AMERICA, ) KELLY L. STEPHENS, Clerk ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR THE ) EASTERN DISTRICT OF KENTUCKY PATRICK HOWARD BRADY, ) Defendant-Appellant. ) OPINION )

Before: GILMAN, DAVIS, and MATHIS, Circuit Judges.

RONALD LEE GILMAN, Circuit Judge. Patrick Howard Brady pleaded guilty to

producing a visual depiction of a minor engaged in sexually explicit conduct. He appeals the

reasonableness of his 300-month sentence. For the reasons set forth below, we AFFIRM the

judgment of the district court.

I. BACKGROUND

From 2022 to 2023, Brady, a high-school band director, engaged in a sexual relationship

with one of his underage students, including the production of sexually explicit videos. Brady

pleaded guilty to one count of production of a visual depiction of a minor engaged in sexually

explicit conduct, in violation of 18 U.S.C. § 2251(a). The Probation Department, based on its

Sentencing Guidelines calculations, recommended sentencing Brady to the statutory maximum of

360 months of imprisonment. No. 24-5940, United States v. Brady

Brady did not dispute the accuracy of the Probation Department’s calculations. In his

sentencing memorandum, he instead argued that several factors weighed in favor of a downward

sentencing variance, including his lack of criminal history, the hours devoted to his career as a

band director, financial problems, domestic issues, depression, and weight gain.

Brady also argued that almost every crime of this nature involves the use of a computer,

making the advisory Guidelines range greater than necessary to satisfy the purposes of sentencing.

He contended that he should receive a downward sentencing variance to counteract the U.S.S.G.

§ 2G2.1(b)(6)(B)(ii) use-of-a-computer enhancement that was applied to his Guidelines range.

Without this enhancement, his Guidelines range would have been 292–360 months of

imprisonment instead of 360 months to life.

At sentencing, the district court stated: “I have received a sentencing memorandum from

the United States, and I have received a sentencing memorandum from the defense. I have read

them all and will give them appropriate weight.” The court then addressed defense counsel: “I

understand your sentencing memorandum[.] I think your point about the electronic device goes

really to the fact that these weren’t transmitted to anyone else. These electronic communications

were between the defendant and the victim; is that correct?” Defense counsel confirmed that the

electronic communications had not been distributed or shared.

The district court emphasized that Brady, as a teacher, held “a particularly important

public trust” with “particular power and influence” over students. It noted that Brady’s conduct

caused harm not only to the victim, but also to her family and friends, and that “[t]here is a streak

of harm here that goes in so many directions that it is hard, really, to get your head around.” The

court further stated that “I came into this courtroom fully prepared to impose a sentence of 360

months. . . . [I]t’s the bottom of the federal sentencing guidelines, which are 360 to life.” But the

-2- No. 24-5940, United States v. Brady

court also remarked that “justice can be tempered with mercy” and explained that “I am also

comforted by the fact that there were no transmissions of these computer . . . images in that they

were not dispersed as we see in so many of these cases.” It then noted that “the ends of public

protection can be met by imposing a term of lifetime supervision, so that we can protect the public

from further crimes of this defendant.”

Ultimately, the district court concluded: “Any sentence I impose will be a serious, serious

sentence, but I am prepared to make a variance at this point.” It proceeded to grant a downward

variance of 60 months, noting that this “seems reasonable under the circumstances.” The resulting

sentence was 300 months of imprisonment. When asked by the court if there was “any legal reason

[that the] sentence should not be imposed as stated,” defense counsel answered that there was not.

This timely appeal followed.

II. ANALYSIS

A. Standard of review

“A criminal sentence must be both procedurally and substantively reasonable.” United

States v. Parrish, 915 F.3d 1043, 1047 (6th Cir. 2019) (citing United States v. Morgan, 687 F.3d

688, 693 (6th Cir. 2012)). “Procedural reasonableness requires the court to ‘properly calculate the

guidelines 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.’” Id. (quoting United

States v. Rayyan, 885 F.3d 436, 440 (6th Cir. 2018)). Here, the district court asked the parties at

sentencing whether they had any objections to the sentence, and defense counsel raised no

objection. We therefore review any procedural-unreasonableness claims under the plain-error

standard. See id. at 1048.

-3- No. 24-5940, United States v. Brady

We review claims of substantive unreasonableness under the abuse-of-discretion standard.

Id. at 1047. “The essence of a substantive-reasonableness claim is whether the length of the

sentence is ‘greater than necessary’ to achieve the sentencing goals set forth in 18 U.S.C.

§ 3553(a).” United States v. Tristan-Madrigal, 601 F.3d 629, 632–33 (6th Cir. 2010). “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) (citation omitted). “The defendant shoulders the burden of

showing substantive unreasonableness.” United States v. Woodard, 638 F.3d 506, 510 (6th Cir.

2011). On appellate review, a within-Guidelines sentence is presumptively reasonable. United

States v. Vonner, 516 F.3d 382, 389 (6th Cir. 2008) (en banc). And “[a]lthough it is not impossible

to succeed on a substantive-reasonableness challenge to a below-guidelines sentence, defendants

who seek to do so bear a heavy burden.” United States v. Greco, 734 F.3d 441, 450 (6th Cir.

2013).

B. The reasonableness of Brady’s sentence

Brady contends that the district court abused its discretion by imposing a substantively

unreasonable sentence.

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United States v. Tristan-Madrigal
601 F.3d 629 (Sixth Circuit, 2010)
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734 F.3d 441 (Sixth Circuit, 2013)
United States v. Vonner
516 F.3d 382 (Sixth Circuit, 2008)
United States v. Conatser
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