United States v. Lorenzo Watson

── United States v. Lorenzo Watson ── Court: Court of Appeals for the Sixth Circuit Date: May 15, 2026 Category: General NOT RECOMMENDED FOR PUBLICATION File Name: 26a0215n.06 No. 25-3272 UNITED STATES COURT OF APPEALS FILED May 15, 2026 FOR THE SIXTH CIRCUIT KELLY L. STEPHENS, Clerk ) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE ) NORTHERN DISTRICT OF LORENZO D. WATSON, ) OHIO Defendant-Appellant. ) ) OPINION ) Before: COLE, GRIFFIN, and READLER, Circuit Judges. GRIFFIN, J., delivered the opinion of the court in which READLER, J., concurred. COLE, J. (pp. 7–8), delivered a separate opinion concurring in part and dissenting in part. GRIFFIN, Circuit Judge. While on federal supervised release, Lorenzo D. Watson was convicted in state court of murder, attempted murder, and felonious assault. The district court sentenced him to 24 months’ imprisonment for these supervised release violations, set to run consecutive to his state sentences. On appeal, Watson argues his sentence is procedurally and substantively unreasonable and violates the Eighth Amendment. We disagree and affirm. I. In 2022, Watson pleaded guilty to possessing a firearm and ammunition as a felon. The district court sentenced him to 16 months’ imprisonment followed by three years of supervised release. No. 25-3272, United States v. Watson Watson absconded while on supervised release and failed to maintain contact with his probation officer. He also went on a violent crime spree. Watson was convicted in state court of two counts of murder, two counts of felonious assault, and one count of attempted murder. For his two murder convictions, Watson was sentenced to life in prison with the possibility of parole after 30 years. His other state sentences for attempted murder and felonious assault were shorter, and the state court ordered them all to run concurrently. So, in theory, Watson could be paroled after serving a 30 year sentence for his state crimes. In federal court, the only contested issue at the supervised release violation hearing was whether Watson’s sentence would run concurrent or consecutive to his state sentences. Considering Watson’s state sentences, his request for a concurrent sentence in federal court would result in no extra prison time for his supervised release violations. The government argued that Watson’s sentence should be consecutive to any state sentence due to “the absolutely despicable and heinous nature of [Watson’s] conduct” while out on supervised release. The government described how Watson shot one man in the back, a second in the stomach, a third in the face, and how he nearly caved in a fourth man’s head. As the district court imposed its sentence, it stressed that Watson’s murder spree took place while the court was “responsible to the community for [him.]” The district court noted that, despite its 26 years on the bench, no one else had committed murder while on supervised release, and it explained that