Sentencing Guidelines

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7^th Circuit Court of Appeals

Case Name: United States of America v. Travis Gates

Case No.: 21-3314

Officials: WOOD, ST. EVE, and KIRSCH, Circuit Judges.

Focus: Sentencing Guidelines

Gates split up with his girlfriend, B.F., and began violently threatening her, and vandalized the house where she was staying. The district court calculated the advisory Sentencing Guidelines range as 18–24 months in prison but sentenced Gates to 48 months, an upward variance Gates challenges on appeal. Because Gates’s sentence was procedurally sound and substantively reasonable, it affirms.

Despite Gates’s long criminal record, the Guidelines assigned him just one criminal history point; with a four-level increase for using a firearm in connection with a felony offense, his Guidelines range was 18–24 months. The district court determined that an upward variance was appropriate, citing several 18 U.S.C. 3553(a) factors and a “pattern of escalating violence.” The Seventh Circuit affirmed his 48-month sentence. Gates’s sentence was procedurally sound and substantively reasonable.

Affirmed

Decided 10/19/22

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