Whether a district court commits plain error by relying to any extent on a defendant's rehabilitative needs in imposing a prison term

QUESTION PRESENTED In Tapia v. United States, 564 U.S. 319, 321 (2011), this Court held that the Sentencing Reform Act of 1984 “precludes federal courts from imposing or lengthening a prison term in order to promote a criminal defendant’s rehabilitation.” A court must not even “consider” rehabilitation when sentencing an offender to prison “because imprisonment is not an appropriate means of pursuing that goal.” Jd. at 328. Tapia has generated a circuit split over the following question presented: whether, as five circuits hold, a district court commits “plain” error—i.e., clear or obvious error—by relying to any extent on a defendant’s rehabilitative needs in imposing a prison term, or whether, as six other circuits hold, a district court commits no “plain” error (and, in some of these circuits, no error at all) unless rehabilitation is the “primary consideration,” “dominant factor,” or “driving force” behind the prison sentence. i