In the

    United States Court of Appeals
                For the Seventh Circuit
                    ____________________
No. 24-2000
UNITED STATES OF AMERICA,
                                                  Plaintiff-Appellee,
                                v.

DEAUNTA SENTREL TYLER,
                                              Defendant-Appellant.
                    ____________________

        Appeal from the United States District Court for the
                      Central District of Illinois.
        No. 4:17-cr-40011-SLD-1 — Sara Darrow, Chief Judge.
                    ____________________

       ARGUED APRIL 3, 2025 — DECIDED JUNE 5, 2025
                ____________________

   Before HAMILTON, BRENNAN, and SCUDDER, Circuit Judges.
    HAMILTON, Circuit Judge. Defendant-appellant Deaunta
Tyler was convicted by a jury of attempted Hobbs Act rob-
bery, possessing a firearm in furtherance of a crime of vio-
lence, and unlawful possession of a firearm as a convicted
felon. The Supreme Court then held in United States v. Taylor,

, 858–59 (2022), that attempted Hobbs Act robbery
does not qualify as a “crime of violence” for purposes of 

(c). Tyler moved to vacate his conviction on the
2                                                 No. 24-2000

charge of possessing a firearm in furtherance of a crime of vi-
olence. The district court granted the motion, set aside the
§ 924(c) conviction, and resentenced Tyler on the two remain-
ing counts to a shorter but still substantial overall sentence.
Tyler now appeals his revised sentence. He contends that the
district court failed to address his key arguments in mitiga-
tion and provided an inadequate explanation for the sentence
imposed. We affirm. Tyler waived any procedural objection
regarding the court’s supposed failure to consider and ad-
dress his arguments in mitigation by telling the court that it
had addressed his principal points. Further, the district court
adequately explained its reasons for imposing a revised sen-
tence within the guideline range.
I. Factual and Procedural History
    In January 2017, Deaunta Tyler, accompanied by Ledell
Tyler and Dalvent Jackson, forcibly entered a home in Rock
Island, Illinois, armed with a rifle and a handgun and in
search of cocaine. Instead of drugs, they found a family
spending a quiet evening together. With weapons bran-
dished, the intruders demanded to know where the cocaine
was. None existed, so the victims could not provide an an-
swer. Nevertheless, Tyler and his accomplices moved the
family throughout the house at gunpoint looking for drugs.
As they searched in vain, the intruders passed the two fire-
arms among themselves and threatened to kill the victims. At
one point, Jackson fired the handgun in the foyer of the home.
The three men remained for about an hour, eventually leaving
with a few hundred dollars in cash and a small amount of ma-
rijuana.
   Law enforcement responded to the scene after being noti-
fied. The next day, police officers identified the three men in
No. 24-2000                                                  3

downtown Rock Island. A high-speed chase ensued, with ap-
pellant Tyler driving the getaway vehicle. He drove the
wrong way down a one-way street for several blocks and,
while speeding around a corner, lost control and crashed.
Jackson and Ledell Tyler quickly surrendered, but appellant
Tyler fled on foot. Officers eventually subdued him. The fire-
arms used during the robbery were found in the wrecked ve-
hicle.
   In February 2017, a grand jury indicted appellant Tyler on
three counts. Count One charged Tyler with attempted Hobbs
Act robbery in violation of 

. Count Two
charged him with possession of a firearm in furtherance of a
crime of violence in violation of 

(c). Count
Three charged him with being a felon in possession of a fire-
arm in violation of 

(g)(1). Count One carried a
maximum prison term of twenty years. Count Two required
a mandatory minimum sentence of ten years to be served con-
secutively. Count Three carried a maximum prison term of
ten years. Tyler’s co-defendants were charged with the same
offenses, and a jury found the three men guilty on all counts.
    In April 2018, the district court held a joint sentencing
hearing for appellant Tyler and accomplice Jackson. Both
faced a Sentencing Guidelines range of 360 months (thirty
years) to life in prison, and the government recommended a
360-month sentence for each. The government emphasized
that Jackson’s conduct was the most aggravated. He fired a
gun during the robbery, acted in the most threatening man-
ner, and later tried to obstruct justice by directing his girl-
friend to influence a witness improperly. Although Tyler’s
conduct was comparatively less severe, it was still serious. He
willingly participated in the attempted robbery, handled the
4                                                  No. 24-2000

firearms, led police on a high-speed chase that ended in a se-
rious crash, and resisted arrest. He also had a prior federal
drug conspiracy conviction, for which he had avoided a man-
datory minimum and received a below-guideline sentence.
   The court sentenced Jackson first, describing him as “the
leader of this operation.” It called the offense “incredibly dis-
turbing,” noting that the defendants had broken into a home
and terrorized a family at gunpoint for nearly an hour. The
court also emphasized that Jackson fired a firearm inside the
house and had an extensive criminal history. The court sen-
tenced Jackson to a total of 360 months in prison: concurrent
terms of 240 months for attempted Hobbs Act robbery and 120
months for firearm possession, followed by a mandatory con-
secutive 120-month term for the conviction under § 924(c).
    Turning to Tyler, the court observed that many of its ear-
lier comments applied equally. The offense was “incredibly
serious,” had a lasting impact on the victims, and the defend-
ants had passed firearms among themselves during the rob-
bery. The court also noted Tyler’s “long string of uninter-
rupted criminal activity,” repeated failures on supervision,
and placement in the highest criminal-history category. Em-
phasizing the value of the Guidelines in avoiding unwar-
ranted disparities, the court found that a sentence “slightly
less” than Jackson’s was appropriate. Accordingly, the court
sentenced Tyler to a total of 330 months: concurrent terms of
210 and 120 months on Counts One and Three, followed by
the mandatory consecutive 120-month sentence on Count
Two under § 924(c).
    Two months later, the court sentenced co-defendant
Ledell Tyler to a total of 180 months—60 months on the
attempted robbery and firearm possession counts and a
No. 24-2000                                                   5

consecutive 120-month term under § 924(c). All three
defendants filed direct appeals, but we dismissed them when
all three of their lawyers filed Anders briefs asserting that no
non-frivolous challenges were available. United States v. Tyler,

 (7th Cir. 2019); see generally Anders v.
California, 

 (1967).
    In July 2022, appellant Tyler moved to vacate his sentence
under 

, arguing that, in light of United States
v. Taylor, 

 (2022), an attempted Hobbs Act robbery
no longer qualified as a crime of violence under 

(c). The government agreed, and the district court
granted the motion. The court vacated Tyler’s § 924(c) convic-
tion and scheduled resentencing on the remaining counts. Ty-
ler faced a new guideline range of 210 to 262 months. At re-
sentencing, he objected to several enhancements, arguing
that, because attempted Hobbs Act robbery was not categori-
cally a crime of violence, no violence-related enhancements
should apply. The court disagreed, emphasizing that it still
must consider the offense conduct when applying the Guide-
lines. The government urged the court to impose a new sen-
tence that mirrored the original term, consistent with the re-
duction granted to co-defendant Ledell Tyler after his § 924(c)
conviction was also vacated. The court acknowledged that,
although the offense no longer qualified as a “crime of vio-
lence” under the categorical approach, the defendants’ actual
conduct was in fact “extremely violent.” Tyler, for his part,
argued for a 120-month sentence, highlighting his supposedly
lesser role in the offense.
    The court thoroughly reviewed the sentencing factors and
reaffirmed its prior assessment that Tyler’s conduct remained
serious despite the vacating of the § 924(c) conviction. The
6                                                            No. 24-2000

court emphasized the profound impact on the victims, Tyler’s
attempt to flee, and his history of criminal behavior. It also
noted that Tyler’s post-sentencing conduct was mixed—he
was involved in an altercation with another inmate but also
attended prison programs. The court ultimately imposed a to-
tal sentence of 240 months, including concurrent terms of 240
months on Count One and 120 months on Count Three. The
new sentence amounted to a 90-month reduction from Tyler’s
original sentence.
   Tyler has appealed his revised sentence. During the pen-
dency of Tyler’s appeal, the district court also resentenced co-
defendant Jackson to consecutive terms of 240 months and 48
months on the remaining counts, for a total sentence of 288
months in prison.
II. Analysis
   Tyler challenges his sentence on two grounds. First, he ar-
gues that the district court failed to address his principal ar-
guments in mitigation. Second, he asserts that the court pro-
vided an inadequate explanation for his sentence. 1 The gov-
ernment counters that Tyler waived any objection to the
court’s treatment of his arguments in mitigation and that,
even in the absence of waiver, the sentencing explanation sat-
isfies the requirements of 

(c). We start with the
dispute about waiver.




    1 In his opening brief, Tyler also contested the substantive reasonable-

ness of his within-guideline sentence. Because he later withdrew the argu-
ment, we do not address it.
No. 24-2000                                                    7

   A. Waiver
    By confirming that the court had addressed sufficiently his
arguments in mitigation, Tyler waived a challenge based on a
supposed failure to do so. A little history may be useful. In
United States v. Cunningham, 

 (7th Cir. 2005),
we wrote that, when imposing a sentence, a district court
must generally address a defendant’s principal arguments in
mitigation. Courts are afforded broad discretion during sen-
tencing, but the record must show that the court actually ex-
ercised that discretion. See, e.g., United States v. Miranda, 

, 792–94 (7th Cir. 2007) (remanding for resentencing
where district court failed to address defendant’s principal,
non-frivolous argument for a lower sentence based on well-
documented and severe mental health problems); Cunning-
ham, 429 F.3d at 679–80 (ordering resentencing because sen-
tencing court “passed over in silence the principal argument
made by the defendant even though the argument was not so
weak as not to merit discussion”); see generally Carr v.
O'Leary, 

 (7th Cir. 1999) (“a discretionary
ruling … cannot be upheld when there is no indication that
the judge exercised discretion”), citing Foman v. Davis, 

 (1962).
    We then began to see numerous appeals invoking the Cun-
ningham principle. Because a sentencing judge’s explanation
of the reasons for a sentence often came last in time, defend-
ants did not have opportunities to raise the Cunningham prin-
ciple when it would do the most good—when the judge could
cure any problem. We encouraged sentencing judges to ask
defense counsel whether they were satisfied that the court
had addressed their principal arguments in mitigation, so that
any further explanation could be provided on the spot rather
8                                                     No. 24-2000

than a year or more later after an appeal. See United States v.
Garcia-Segura, 

, 568–69 (7th Cir. 2013). If the de-
fense said it was satisfied that the court had addressed the
principal arguments in mitigation, a challenge under Cun-
ningham would be deemed waived. 

. We soon began
to apply that waiver principle. E.g., United States v. Donelli, 

, 940–41 (7th Cir. 2014), and other progeny of Garcia-
Segura.
    Cunningham and other decisions enforcing the require-
ment that sentencing courts address defendants’ principal,
nonfrivolous arguments do not limit a court’s substantial dis-
cretion in selecting an appropriate sentence under the frame-
work of 

(a). See Donelli, 747 F.3d at 939–40.
Rather, our precedents are designed to ensure that courts
meaningfully address the key arguments influencing sentenc-
ing decisions. 

 This safeguard rests on the principle that a
“judge who fails to mention a ground of recognized legal
merit (provided it has a factual basis) is likely to have com-
mitted an error or oversight.” Cunningham, 

.
   In resentencing Tyler in this case, the district court fol-
lowed the path we encouraged in Garcia-Segura. After explain-
ing the basis for Tyler’s sentence, the court asked defense
counsel: “Have I addressed all of your principal arguments in
mitigation?” Counsel responded that the court had but re-
quested additional explanation regarding its reasons for ap-
plying the contested sentencing enhancements. The court fur-
ther clarified its reasoning and asked: “So does that provide
sufficient clarification?” Defense counsel replied, “Yes,
Judge.” This confirmation waived Tyler’s Cunningham proce-
dural challenge in this appeal. See, e.g., United States v. Perez,

 (7th Cir. 2021) (applying Garcia-Segura
No. 24-2000                                                     9

waiver to argument about unwarranted sentencing dispari-
ties where defense counsel twice responded affirmatively
when asked if the court had addressed principal arguments
in mitigation); Donelli, 747 F.3d at 940–41 (finding waiver). To
be clear, this process results in waiver, which forecloses ap-
pellate review of the point, not mere forfeiture, which could
allow plain-error review. The sentencing court gave defense
counsel more than one opportunity to invite attention to any
overlooked mitigation arguments. He declined. That proce-
dural safeguard—and check against avoidable appeals—is
what we envisioned with the Garcia-Segura path toward
waiver. We turn next to Tyler’s related but distinct argument
that the district court inadequately explained the reasons for
the revised sentence.
   B. The Adequacy of the District Court’s Explanation
    We review de novo a sentence’s procedural reasonable-
ness. United States v. Stephens, 

 (7th Cir.
2021). Our analysis is guided by a practical assessment of the
entire record as well as the defendant’s individual character-
istics. See Concepcion v. United States, 

, 486 (2022).
We do not demand artificial thoroughness in sentencing.
United States v. Sanchez, 

, 540 (7th Cir. 2021). “A
short explanation will suffice where the context and record
make clear the reasoning underlying the district court’s con-
clusion.” United States v. Schroeder, 

 (7th Cir.
2008), citing Rita v. United States, 

 (2007). As
we have said in many cases, a sentencing judge “need not be-
labor the obvious.” E.g., United States v. Caraway, 

 (7th Cir. 2023), quoting United States v. Baker, 

, 1132 (7th Cir. 2023); United States v. Wade, 

,
10                                                  No. 24-2000

632 (7th Cir. 2018), quoting United States v. Reed, 

 (7th Cir. 2017).
    We typically require less explanation when, as here, the
sentence is within the correct guideline range. E.g., United
States v. Curby, 

 (7th Cir. 2010) (affirming sen-
tence where court’s discussion of mitigation arguments was
brief but sentence was at bottom of guideline range). It is
enough if the record gives us confidence that the court mean-
ingfully considered the defendant’s arguments, “even if im-
plicitly and imprecisely.” United States v. Diekemper, 

 (7th Cir. 2010). A sentencing court must “set forth
enough to satisfy the appellate court that [it] has considered
the parties’ arguments and has a reasoned basis for exercising
[its] own legal decisionmaking authority.” Rita, 

, citing United States v. Taylor, 

, 336–37 (1988).
    The district court met that standard here. Despite receiv-
ing positive responses to its Garcia-Segura inquiries, the court
nonetheless addressed Tyler’s principal mitigation argu-
ment—that he was less culpable than his co-defendants—and
the other factors affecting the sentence. The court acknowl-
edged that Tyler was less violent than his co-defendants in
some respects but emphasized the overall violent nature of
the offense. It also underscored his resisting arrest, substantial
criminal history, heightened risk of recidivism, and mixed
disciplinary record while in custody. After weighing the
§ 3553(a) factors, the court imposed a within-guideline sen-
tence. The Supreme Court has upheld sentences supported by
far less detailed reasoning. See, e.g., Chavez-Meza v. United
States, 

, 118–20 (2018) (holding that sentencing
court’s “minimal” explanation of sentencing modification
was sufficient); Rita, 551 U.S. at 356–58 (upholding sentence
No. 24-2000                                                 11

where judge explained simply that the guideline sentence im-
posed was “appropriate” and noting that the “law leaves
much” to “the judge’s own professional judgment” with re-
spect to the depth of a sentencing explanation). The district
court’s explanation here easily met the standard established
by precedent for procedural reasonableness.
   This case offers a useful reminder, though: We reaffirm
that a Garcia-Segura waiver bars procedural objections based
on the court’s alleged failure to address a defendant’s princi-
pal arguments in mitigation when counsel confirms that the
court has considered those arguments. It may be prudent in
the future for courts to repeat the Garcia-Segura question, as
Chief Judge Darrow did here, if substantive exchanges take
place in response to the question when first asked. A brief, on-
the-record confirmation that the court has considered a de-
fendant’s principal arguments is a simple yet powerful tool to
promote perceived fairness in sentencing and to avoid unnec-
essary appeals.
                                                  AFFIRMED.