Seventh Circuit on limited remands and reasonableness
The Seventh Circuit today in US v. Della Rose, No. 03-4230 (7th Cir. Jan. 25, 2006) (available here), thoughtfully discusses the procedures surrounding Booker limited remands and the reasonableness of a sentence in a mail fraud case. Though the defendant’s claims are rejected, other defendants might find sweet the smell of some of the dicta in Della Rose. For example, the Della Rose court says district courts have “much broader discretion” after Booker and it says that district courts can now give factors such as community contributions and collateral consequences “much more weight than the Guidelines themselves would have allowed.”
Also, fans of intricate issues of guideline interpretation will also want to check out the Seventh Circuit’s work today in US v. Chamness, No. 05-1902 (7th Cir. Jan. 25, 2006) (available here).