Background
Zakaria Pathiong Joseph-Majak pleaded guilty in 2017 to possessing a stolen firearm. The district court sentenced him to 84 months in prison followed by three years of supervised release.
While serving that supervised-release term in 2025, Joseph-Majak pleaded guilty to two new federal offenses and received a sentence of 228 months in prison followed by five years of supervised release. After he admitted that the new crimes violated a condition of his existing supervised release, the district court revoked that release and imposed 24 months in prison, with no additional supervised release. Joseph-Majak appealed, arguing that the revocation sentence was unreasonable.
The Court’s Holding
The Fourth Circuit affirmed. Applying its rule that a revocation sentence will be upheld if it falls within the statutory range and is not plainly unreasonable, the court first considered whether the sentence was unreasonable at all.
The court held that the sentence was procedurally reasonable because the district court correctly calculated the applicable Sentencing Guidelines policy-statement range and sufficiently explained its choice of sentence. It also held that the sentence was substantively reasonable because the 24-month term fell within that policy-statement range and was supported by the circumstances.
Key Takeaways
- A district court has broad discretion when sentencing a defendant after revoking supervised release.
- A revocation sentence is procedurally reasonable when the court correctly calculates the Chapter Seven policy-statement range, considers the applicable factors and potentially meritorious arguments, and adequately explains the sentence.
- The Fourth Circuit found Joseph-Majak’s within-policy-statement-range 24-month sentence both procedurally and substantively reasonable.
Why It Matters
The unpublished decision reinforces the deferential review applied to supervised-release revocation sentences. A district court need not explain a revocation sentence as extensively as an original sentence, but it must provide enough reasoning to show that it considered the governing policy statements, statutory factors, and material arguments.