Broughton was charged in 2022 with violating 18 U.S.C. § 922(g)(1). The underlying incident occurred on June 15, 2021, when an Atlanta police officer heard gunshots at a motel and found Broughton holding a silver pistol. Broughton threw the gun over a fence and attempted to flee but was tased and detained.
Security footage showed Broughton and another individual, Lavonta Broughton, sitting in a vehicle. Lavonta exited and shot at Nathaniel Broughton, who then fired one shot in return. Investigation confirmed the pistol had traveled in interstate commerce and that Nathaniel Broughton was a convicted felon.
At sentencing, the district court initially considered the Armed Career Criminal Act (ACCA) enhancement but ultimately agreed with Broughton that it did not apply under Erlinger v. United States, 602 U.S. 821 (2024), because Broughton had not admitted his prior qualifying offenses occurred on separate occasions.
The court calculated Broughton’s guideline range at 77 to 96 months based on a base offense level of 24 and criminal history category VI. Broughton argued for a downward variance citing his difficult upbringing, mental health diagnoses, and substance abuse history, requesting a 60-month sentence.
The government requested a sentence in the middle of the guideline range, noting Broughton’s extensive criminal record and the fact that his firearm was discharged. The district court adopted the government’s recommendation, imposing an 87-month sentence to protect the public and reflect the seriousness of the offense.
Broughton appealed, arguing the sentence was unreasonable. The Eleventh Circuit reviewed the sentence for procedural and substantive reasonableness, finding no significant procedural error and concluding the sentence was within the range of permissible outcomes.
The appellate court affirmed the sentence but remanded for the limited purpose of allowing the district court to correct a clerical error in the judgment.