In United States v. Pyles, Pyles pled guilty to one count of aiding and abetting the distribution of crack cocaine. Although the advisory guideline range called for 63-78 months’ imprisonment, the district court imposed a variance sentence of 5 years’ probation with 6 months’home confinement. The district court viewed probation as an appropriate sentence because Pyles was off drugs, off alcohol, was holding a job, and seemed to have reformed himself. The government appealed the sentence.
The Fourth Circuit concluded that in rejecting a sentence of imprisonment, the district court failed to place sufficient weight on "the need for the sentence imposed . . . to reflect the seriousness of the offense . . . and to provide just punishment for the offense," under 18 U.S.C.A. § 3553(a)(2)(A). The panel also chastised the district court for rejecting the Sentencing Commission’s judgment that an offense involving crack cocaine is a serious offense that must be punished by a meaningful sentence of imprisonment. The sentence was vacated and remanded for resentencing.