United States v. Robert Willis, Jr.

CourtCourt of Appeals for the Eleventh Circuit
DecidedFebruary 5, 2026
Docket25-10822
StatusUnpublished

This text of United States v. Robert Willis, Jr. (United States v. Robert Willis, Jr.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh 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. Robert Willis, Jr., (11th Cir. 2026).

Opinion

USCA11 Case: 25-10822 Document: 25-1 Date Filed: 02/05/2026 Page: 1 of 7

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-10822 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus

ROBERT WILLIS, JR., Defendant-Appellant. ____________________ Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 0:22-cr-60067-RS-1 ____________________

Before NEWSOM, BRASHER, and WILSON, Circuit Judges. PER CURIAM: Defendant-Appellant Robert Willis, Jr. appeals the district court’s denial of his motion to reduce his sentence, pursuant to 18 USCA11 Case: 25-10822 Document: 25-1 Date Filed: 02/05/2026 Page: 2 of 7

2 Opinion of the Court 25-10822

U.S.C. § 3582(c)(2) and based on Amendment 821 to the Sentenc- ing Guidelines. He contends that the district court failed to provide a basis for meaningful appellate review and that it abused its discre- tion by denying relief. After careful review, we affirm. I. Where § 3582(c)(2) applies, we review the district court’s de- cision to grant or deny a sentence reduction for abuse of discretion. United States v. Caraballo-Martinez, 866 F.3d 1233, 1238 (11th Cir. 2017). An abuse of discretion arises if the district court “applies an incorrect legal standard, follows improper procedures in making the determination, or makes findings of fact that are clearly erro- neous.” United States v. Jordan, 582 F.3d 1239, 1249 (11th Cir. 2009) (per curiam) (quotation marks omitted). II. A district court may modify a defendant’s term of imprison- ment if the defendant was sentenced based on a sentencing range that has subsequently been lowered by the Sentencing Commis- sion. 18 U.S.C. § 3582(c)(2). “This authority is limited to those guideline amendments listed in U.S.S.G. § 1B1.10(c) that have the effect of lowering the defendant’s applicable guideline range.” United States v. Williams, 557 F.3d 1254, 1256 (11th Cir. 2009) (per curiam) (quotation marks omitted). The applicable policy state- ment for § 3582(c)(2) motions is U.S.S.G. § 1B1.10. United States v. Bryant, 996 F.3d 1243, 1256 (11th Cir. 2021). In considering whether to “reduce the term of imprison- ment of an already incarcerated defendant when that defendant USCA11 Case: 25-10822 Document: 25-1 Date Filed: 02/05/2026 Page: 3 of 7

25-10822 Opinion of the Court 3

was sentenced based on a sentencing range that was subsequently lowered by the Sentencing Commission,” a district court must en- gage in a two-step analysis: (1) recalculating the guideline range un- der the amended guidelines; and (2) deciding whether, in its discre- tion, it should reduce the defendant’s sentence considering the § 3553(a) factors. 1 United States v. Bravo, 203 F.3d 778, 780–81 (11th Cir. 2000). Because each condition is necessary, the failure to sat- isfy any one condition warrants denial of a motion for a sentence reduction. See United States v. Tinker, 14 F.4th 1234, 1237–38 (11th Cir. 2021) (per curiam). In November 2023, Amendment 821 to the Sentencing Guidelines went into effect. 2 See U.S. Sentencing Com- mission, Adopted Amendments (Effective November 1, 2023), Amend- ment 821.

1 The factors include the nature and circumstances of the offense, the history

and characteristics of the defendant, and the need for the sentence imposed to reflect the seriousness of the crime, promote respect for the law, provide just punishment for the offense, afford adequate deterrence, and protect the public from further crimes of the defendant. 18 U.S.C. § 3553(a). 2 As relevant here, the Guidelines were amended to limit the effect of criminal

history “status points” on a defendant’s sentence. Now, only one point is added “if the defendant (1) receives 7 or more points under § 4A1.1(a) through (d), and (2) committed any part of the instant offense (i.e., any relevant con- duct) while under any criminal justice sentence.” U.S.S.G., Supp. App. C, Amend. 821. Previously, the Guidelines added two points when a defendant committed the instant offense while under a criminal justice sentence. U.S.S.G. § 4A1.1(d) (2021). USCA11 Case: 25-10822 Document: 25-1 Date Filed: 02/05/2026 Page: 4 of 7

4 Opinion of the Court 25-10822

III. First, Willis argues that the district court’s order failed to provide an individualized explanation, address whether he was eli- gible under Amendment 821, discuss the § 3553(a) factors, or en- gage with the relevant filings. Willis moved for a reduced sentence under 18 U.S.C. § 3582(c)(2) and Amendment 821 to the Sentenc- ing Guidelines. The government responded, agreeing that Willis would be eligible for relief under Amendment 821, but that a sen- tence reduction was unwarranted under the § 3553(a) factors. Alt- hough Willis did not mention the factors in his initial motion, in his reply, Willis pointed to the unwarranted sentence disparity with his current sentence and to his participation in education courses, rehabilitation programs, and substance abuse treatment. In a pa- perless order, the district court made the following determination: “The Court having considered the record as a whole, including the factors in § 3553(a), the Defendant’s Motion is Denied.” When a district court considers the § 3553(a) factors, it need not explicitly discuss each of them nor state on the record that it has explicitly considered each of them. United States v. Kuhlman, 711 F.3d 1321, 1326 (11th Cir. 2013). The district court need not articulate its findings and reasoning in detail as long as in light of the record, it is clear that the district court considered the relevant factors. See United States v. Douglas, 576 F.3d 1216, 1219–20 (11th Cir. 2009) (per curiam). An acknowledgment that the court con- sidered all applicable § 3553(a) factors, along with “enough analysis USCA11 Case: 25-10822 Document: 25-1 Date Filed: 02/05/2026 Page: 5 of 7

25-10822 Opinion of the Court 5

that meaningful appellate review of the factors’ application can take place,” is sufficient. Id. at 1240–41 (quotation marks omitted). In the context of an amendment to a different guideline, our decision in Douglas held that a district court’s failure to consider the § 3553(a) factors constituted reversible error because there was in- sufficient evidence that the district court had considered the sen- tencing factors given that the defendant’s motion barely referenced the § 3553(a) sentencing factors and the government did not re- spond to the defendant’s motion. Id. By contrast, in another case, we affirmed a § 3582 decision where the district court explained that it considered the prisoner’s motion, which presented argu- ments about why the sentencing factors supported imposing a more lenient sentence and the government responded to those ar- guments. United States v.

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Related

United States v. Eggersdorf
126 F.3d 1318 (Eleventh Circuit, 1997)
United States v. Bravo
203 F.3d 778 (Eleventh Circuit, 2000)
United States v. Williams
557 F.3d 1254 (Eleventh Circuit, 2009)
United States v. Smith
568 F.3d 923 (Eleventh Circuit, 2009)
United States v. Douglas
576 F.3d 1216 (Eleventh Circuit, 2009)
United States v. Jordan
582 F.3d 1239 (Eleventh Circuit, 2009)
United States v. Rick A. Kuhlman
711 F.3d 1321 (Eleventh Circuit, 2013)
United States v. Pedro Rafael Caraballo-Martinez
866 F.3d 1233 (Eleventh Circuit, 2017)
United States v. Thomas Bryant, Jr.
996 F.3d 1243 (Eleventh Circuit, 2021)
United States v. Delvin Tinker
14 F.4th 1234 (Eleventh Circuit, 2021)

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