Appeal from the United States District Court for the Southern District of Ohio at Columbus.
No. 2:14-cr-00127-19—Algenon L. Marbley, District Judge.
Argued: June 13, 2024
Decided and Filed: September 9, 2024
Before: GIBBONS, WHITE, and MURPHY, Circuit Judges.
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OPINION
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MURPHY, Circuit Judge. Just weeks before he turned eighteen, Johnathan Holt shot and
killed a drug dealer on behalf of a dangerous gang. Soon after this murder, Holt himself suffered
gun violence that left him paralyzed from the chest down. A federal jury later convicted him of
two crimes for the murder. A district court sentenced him to a mandatory term of life in prison.
Yet Holt had committed the murder as a juvenile, so this sentence violated the Eighth
Amendment under Miller v. Alabama, 567 U.S. 460 (2012). The district court thus granted
Holt’s request for relief from his life sentence. It resentenced him to a total of 900 months’
imprisonment.
Holt now raises two general challenges to this new sentence. First, he argues that it still
violates the Eighth Amendment both because the district court did not adequately address his
youth and because the Bureau of Prisons has not properly treated his paraplegia. But the
Supreme Court’s caselaw requires district courts only to consider a defendant’s youth. The
district court here did so. Holt also raises his medical-based Eighth Amendment claim in the
wrong venue: a criminal appeal challenging his prison sentence rather than a civil suit
challenging his medical care. Second, Holt argues that his sentence is procedurally and
substantively unreasonable when measured against the requirements in Federal Rule of Criminal
Procedure 32 and the sentencing factors in 18 U.S.C. § 3553(a). Yet Holt did not adequately
preserve most of his procedural claims. And the court’s lengthy sentence reasonably fit Holt’s
brutal crime. We thus affirm. |