Does a sentencing court violate the Sentencing Reform Act when it relies on rehabilitation as a reason to impose prison time?

QUESTION PRESENTED In Tapia v. United States, 564 U.S. 319 (2011), this Court held that the Sentencing Reform Act bars federal courts from imposing or lengthening a prison term to promote a criminal defendant’s rehabilitation. Circuits are split on how to apply the Sentencing Reform Act after Tapia. Does a sentencing court violate the Sentencing Reform Act only when rehabilitation is the “primary consideration” behind a prison sentence, as the Seventh Circuit held below and as is the rule in the First, Second, Third, Fourth, Fifth, and Eighth Circuits? Or does the act prohibit sentencing courts from relying even in part on rehabilitation as a reason to impose prison time, as is the rule in the Sixth, Ninth, Tenth, and Eleventh Circuits?