Case Explained: Non-Argument Calendar UNITED STATES OF AMERICA v. JOSEPH ELIAS NEHME

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-06-23 Docket: 6:18-cr-00231-PGB-LHP-1 The eleventh-circuit affirmed the district court’s imposition of a 24-month term of reimprisonment following the revocation of Joseph Nehme’s supervised release. The court rejected Nehme’s two primary challenges to the sentence. First, regarding the claim that the district court impermissibly considered retributive factors under 18 U.S.C. § 3553(a)(2)(A), the court applied the plain error standard established in *Esteras v. United States*, 606 U.S. 185 (2025). Under this standard, reversal requires a clear or obvious reliance on the prohibited factors, either expressly or by unmistakable implication. The court found no plain error because the district court explicitly disclaimed consideration of § 3553(a)(2)(A) in its sentencing order and based its decision on Nehme’s failure to comply with supervised release conditions rather than the seriousness of his underlying conviction. Second, regarding the claim of substantive unreasonableness, the court applied the abuse of discretion standard, noting that the weight given to § 3553(a) factors is committed to the district court’s sound discretion. The court held that the district court sufficiently considered the relevant statutory factors and Nehme’s mitigation arguments, particularly his argument against double punishment for state time already served, while appropriately weighing Nehme’s history and characteristics under § 3553(a)(1). Additionally, the sentence fell within the advisory guideline range of 21 to 27 months (reduced to the statutory maximum of 24 months), further supporting its reasonableness. Consequently, the judgment is affirmed, and Nehme must serve the imposed term of reimprisonment followed by three years of supervised release. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.