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Third Circuit finds procedurally(?!?) unreasonable two below-guideline white-collar sentences

By Douglas A. Berman

The Third Circuit has an interesting ruling today in US v. Negroni, No. 10-1050 (3d Cir. March 29, 2011) (available here), in which two white-collar defendants have their below-guideline sentences vacated.  Here are a few snippets from the Negroni opinion that provides an incomplete summary : The United States appeals orders of the United States District Court for the Eastern District of Pennsylvania sentencing Appellee James Hall to fifteen months' imprisonment and Appellee Paul Negroni to five years' probation, including nine months' in-home detention.  Because the District Court committed procedural error in reaching both of those sentences, we will vacate the orders and remand for resentencing.... These consolidated cases spring from a massive fraud scheme organized and conducted by a man named Kevin Waltzer...continue to full post

Full post as published by Sentencing Law and Policy on March 29, 2011 (boomark / email).