US v. Chandia: This is the third appeal for Chandia as to his sentence, imposed following his conviction for providing and conspiring to provide material support to terrorists and a foreign terrorist organization. All the appeals revolve around the district court's application of the "federal crime of terrorism" enhancement in USSG 3A1.4. In the first appeal, the Fourth Circuit vacated Chandia's sentence and remanded for a "fresh analysis" about the enhancement, particularly whether Chandia had the intent necessary to trigger it. In the second appeal, the Fourth Circuit vacated the sentence due to the district court's failure to resolve factual disputes and explain its findings. On remand for the second time, the district court again concluded that the enhancement applied and imposed a sentence of 180 months in prison.
On appeal, Chandia challenged his sentence as procedurally unreasonable. This time, the Fourth Circuit affirmed. First, it rejected Chandia's argument that the factual basis for the enhancement should have been found by clear and convincing evidence due to the severity of the enhancement. Second, it rejected Chandia's argument that the factual basis, even under a preponderance standard, was not sufficient to support the enhancement (the court spends several pages laying out the details of the facts of the case). Finally, the court rejected Chandia's argument that the district court did not adequately consider all the relevant 3553(a) factors before imposing a within-the-Guideline-range sentence.