US v. Centariczki, No. 23-1194 (1st Cir. 2024)
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Edgar Centariczki, the defendant, pleaded guilty to aiding and abetting the distribution of methamphetamine and fentanyl in 2021. He was sentenced to time served (two days) and three years of supervised release. His case was transferred to the District of Maine, where he resided. Between June and October of 2021, Centariczki tested positive for marijuana and cocaine multiple times and missed several probation office appointments. Despite warnings from the court, he continued to violate the terms of his supervised release, leading to his arrest in November. In January 2022, a revocation hearing was held due to multiple violations, including drug and alcohol use and failures to report to probation office appointments.
The District Court for the District of Maine held a final revocation hearing in February 2023. The court calculated a guideline sentencing range of four to ten months, with thirty months of supervised release. However, the government advocated for an above-guidelines sentence of eighteen months' incarceration with no supervised release to follow, arguing that Centariczki had received multiple chances to seek drug treatment and yet continued to violate the terms of his probation. The court agreed and sentenced Centariczki to eighteen months' incarceration with no supervised release to follow.
Centariczki appealed to the United States Court of Appeals for the First Circuit, arguing that his sentence was substantively unreasonable because the district court lacked a sufficiently above-guidelines plausible rationale for imposing an eighteen-month sentence. The Court of Appeals disagreed, holding that the district court's rationale was plausible and its sentence was reasonable. The court noted that Centariczki's repeated violations of his supervised release terms and the multiple second chances afforded to him by the court and probation officer justified the above-guidelines sentence. The court affirmed the district court's decision.
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