Francisco Ortiz v. United States

When a defendant challenges a sentence imposed after revocation of his supervised release, most circuits apply the same “reasonableness” standard of review that would apply to an appeal of an initial sentence. See United States v. Booker, 543 U.S. 220, 260–63 (2005). But the Fourth, Fifth, and Seventh Circuits set a higher burden: a revocation defendant must show that the sentence is unreasonable and that the error is plain under existing precedent. Does the standard of review for revocation appeals require a separate demonstration of plainness? (i)