Whether a party may obtain appellate relief when the district court fails to address substantial arguments for a sentence outside the Guideline range

QUESTION PRESENTED Whether, after Holguin-Hernandez v. United States, _U.S.__, 140 S.Ct. 762 (2020), a party may obtain appellate relief when the district court fails to reference or address substantial arguments for a sentence outside the Guideline range, even if the party had not lodged a specific objection to the court’s failure to do so? Whether a district court errs should reference or address substantial arguments for a sentence outside the Guideline range? Whether, in light of the historical record, Almendarez-Torres v. United States, 523 U.S. 224 (1998), should be overruled? i