Whether the holding in Holguin-Hernandez that a defendant's argument for a lower sentence preserves appellate review of the substantive reasonableness of the sentence should be extended to provide that such an argument also preserves review of a claim that the district court's reasons for the sentence are inadequate

Question Presented This Court in Holguin-Hernandez held that a defendant’s argument in the district court for a lower sentence preserves appellate review to the substantive reasonableness of the sentence imposed. This Court has yet to address whether that holding applies to procedurally unreasonable sentences, such as in this case, where the district court offered no reasons for rejecting a defendant’s comprehensive request for a below-guidelines sentence. On this point, the circuits are split. Given that a sentencing court is obligated not only to provide a substantively reasonable sentence but also to provide adequate reasons for the sentence, should the logic of HolguinHernandez’s holding be extended to provide that an argument for a lower sentence preserves review of a claim that the district court’s reasons for sentence are inadequate? -i