Fourth Circuit: US v. Erick Gibbs

Within-guidelines sentence procedurally reasonable as it was explained and substantively reasonable as there is a basis for it.

Dissent: Nonfrivolous arguments for a downward variance were not addressed; error to conflate the degree to which the sentence is congruent with the guidelines with procedural reasonableness.

http://www.ca4.uscourts.gov/opinions/174037.P.pdf