Case Explained: UNITED STATES OF AMERICA Plaintiff – v. YONATHAN MELAKU Defendant –

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-17 The Fourth Circuit affirmed the district court’s resentencing of Yonathan Melaku, denying his request for relief on four challenges to a 240-month imprisonment term imposed after the vacatur of one count in his original conviction. The court held that two of Melaku’s arguments were forfeited because he failed to raise them during the district court proceedings, while the remaining two claims failed under the applicable standards of review. Regarding the forfeited claims, the court applied the plain-error standard under Federal Rule of Criminal Procedure 52(b). First, Melaku argued that the district court violated 18 U.S.C. § 3582(a) by imposing a sentence to ensure his medical compliance for schizophrenia, citing *Tapia v. United States*. The court rejected this claim at the second prong of the plain-error analysis, finding no “clear or obvious” error. The court reasoned that ensuring a defendant receives necessary medical care for an incurable condition does not plainly constitute “promoting correction and rehabilitation” under § 3582(a), and the district court’s statements regarding public safety and treatment needs did not clearly establish that the sentence length was determined solely to facilitate a rehabilitation program. Second, Melaku argued the district court lacked jurisdiction to order a pre-release hearing; the court held this argument was forfeited because it concerned remedial authority rather than subject-matter jurisdiction, and Melaku failed to object at sentencing or satisfy plain-error review. Regarding the non-forfeited claims, the court reviewed the procedural and substantive reasonableness of the sentence under the deferential abuse-of-discretion standard established in *Gall v. United States*. The court found no abuse of discretion, concluding that the district court did not rely on clearly erroneous facts when characterizing Melaku’s conduct as instilling public fear or assessing his disciplinary history. Furthermore, the court determined the 240-month sentence was substantively reasonable given the serious nature of Melaku’s crimes, including firing at military sites and possessing bomb-making materials, which warranted a significant upward variance from the advisory Guidelines range to protect the public and provide just punishment. As a result of this decision, the judgment of the district court is affirmed, and Melaku remains subject to the 240-month sentence imposed by the district court. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.