The U.S. Court of Appeals for the Fourth Circuit vacated and remanded a criminal sentence in *United States v. Francisco Celedon*, ruling that the district court failed to provide sufficient explanation for imposing the statutory maximum sentence following a supervised release revocation.
In a published opinion dated Jan. 30, 2026, Circuit Judge Gregory wrote for the majority that Francisco Celedon's 36-month revocation sentence was plainly unreasonable. Judge Keenan joined the majority opinion, while Chief Judge Diaz dissented.
"Celedon argues that his revocation sentence is plainly unreasonable because the district court failed to sufficiently explain why it imposed the statutory maximum sentence," Judge Gregory wrote. "We agree."
The case stems from Celedon's original guilty plea on June 16, 2015, to possession with intent to distribute cocaine in violation of 21 U.S.C. § 841(a)(1), as well as reentry of deported aliens. Following his initial sentence, Celedon was placed on supervised release, which was later revoked by the district court.
The U.S. District Court for the Eastern District of Virginia, under Senior District Judge Henry E. Hudson, imposed the 36-month sentence after revoking Celedon's supervised release term. However, the Fourth Circuit found this sentence problematic due to inadequate judicial explanation.
The appellate court's decision highlights the requirement that district courts provide sufficient reasoning when imposing sentences, particularly when selecting the maximum penalty allowed under statute. This principle ensures that defendants and appellate courts can understand the basis for sentencing decisions and evaluate their reasonableness.
Celedon was represented by the Office of the Federal Public Defender in Alexandria, Virginia. Patrick L. Bryant argued the case on appeal, while the brief was prepared by Federal Public Defender Geremy C. Kamens and Assistant Federal Public Defender Amy L. Austin.
The government was represented by the Office of the United States Attorney in Richmond, Virginia. Shea Gibbons argued for the government on appeal, with United States Attorney Jessica D. Aber signing the brief.
The case was argued before the Fourth Circuit on Sept. 26, 2025, with the decision issued approximately four months later. The published nature of the opinion indicates the court viewed the legal issues as having broader significance beyond this individual case.
Chief Judge Diaz's dissent suggests disagreement within the panel regarding either the legal standard for evaluating sentence reasonableness or its application to Celedon's specific circumstances. While the full text of the dissenting opinion is not available in the court record excerpt, dissents in sentencing cases often focus on the appropriate level of deference appellate courts should give to district court sentencing decisions.
The Fourth Circuit's jurisdiction covers federal appeals from district courts in Maryland, North Carolina, South Carolina, Virginia, and West Virginia. The court's decision in *Celedon* will provide guidance to district courts within the circuit regarding the explanation required when imposing maximum sentences following supervised release revocations.
Supervised release violations can result in additional prison time, with the length depending on various factors including the nature of the violation and the defendant's criminal history. The statutory maximum sentence varies based on the underlying offense and other legal considerations.
The vacatur and remand means Celedon's case returns to the Eastern District of Virginia for a new sentencing hearing. At resentencing, the district court will need to provide more detailed reasoning if it chooses to impose the same or similar sentence length.
This decision reflects ongoing judicial scrutiny of sentencing explanations, particularly in cases involving the revocation of supervised release. Courts of appeals regularly review district court sentences for reasonableness, both in terms of the length imposed and the adequacy of the court's explanation.
The case number 23-4701 indicates the appeal was filed in 2023, showing the typical timeframe for federal criminal appeals to move through the system. The original district court case number 3:23-cr-00086-HEH-1 reflects that this was a 2023 criminal case in the Eastern District of Virginia.
For Celedon, the Fourth Circuit's decision provides an opportunity for a potentially reduced sentence if the district court cannot adequately justify imposing the statutory maximum upon reconsideration. The case also serves as a reminder to district courts throughout the Fourth Circuit of their obligation to provide sufficient reasoning for sentencing decisions, particularly when imposing maximum penalties.
The resentencing will require the district court to carefully consider all relevant factors and articulate its reasoning for whatever sentence it ultimately imposes, ensuring compliance with federal sentencing standards and appellate review requirements.