120-month bank robbery sentence held reasonable for ailing defendant

The Third Circuit has upheld as reasonable a 120-month sentence in a bank robbery case in which the defendant has suffered from AIDS since the early 1980s. The defendant in United States v. Watson, No. 05-3892 (3d Cir. Apr. 5, 2007) faced a Guidelines range of 151-188 months, and the district court varied downward on account of the defendant's health, which had deteriorated during his pre-trial detention due to improper management of his medication by prison officials.

The defendant appealed, claiming that 120 months is unreasonably excessive (regardless of the higher Guidelines range) as it amounts to an effective life sentence given his prognosis. The Third Circuit was unpersuaded, noting that "the mere fact that a defendant may not survive beyond his sentence does not provide a basis for a shorter sentence," --- at least not in the court of appeals, under the deferential review accorded sentences post-Booker. The Court noted that the district court gave meaningful consideration to all of the Section 3553(a) factors in determining sentence.

The Court also distinguished its recent decision in United States v. Manzella in rejecting the defendant's claim that the 120 months of imprisonment had been chosen in order to further rehabilitative and treatment goals, in violation of 18 U.S.C. 3582(a). Unlike in Manzella, where there was ample evidence that imprisonment was ordered to further drug treatment, here, the district court merely mentioned the defendant's medical treatment needs in the context of discussing the overall appropriate sentence and the recommended designation to a BOP medical facility.