United States v. Hall, Docket No. 05-6919-cr (Aug. 30, 2007) (found here)
The Second Circuit affirmed the district court's sentence, but remanded to amend the written judgment to comply with 18 U.S.C. § 3553(c)(2) -- the district court judge had given only an oral explanation for the below-Guidelines sentence imposed. Here is the guidance the Second Circuit provides to district courts in putting together their written explanations of reasons (note the question I pose at the bottom):
In requiring sentencing judges to include a statement of reasons in the written judgment under section 3553(c)(2), as we do here, we are not suggesting that judges must denote every fact discussed in the setencing colloquy. Indeed, nothing stated in this opinion should be interpreted to "require the district court to utter any specific incantation." [citation to United States v. Rattoballi, discussed here and here, omitted.] We do not understand Congress's intent in enacting section 3553(c)(2) to have been to divert district courts' attention from conducting a thoughtful, on-the-record, face-to-face sentencing exchange with criminal defendants to obsessing over the inclusion of every material sentencing fact in a written order of judgment. We are, moreover, mindful that the circulation through the Bureau of Prisons of a detailed statement of the facts underlying some reasons can present particular concerns, as for example, when a statement references sensitive information about crime victims, the defendant, or members of his family. Thus, we reiterate that the statutory requirement for specific reasons does not necessarily require an exhaustive statement of facts. Indeed, a simple summary of facts should generally suffice for Bureau of Prisons review. In conducting our own appellate review of the reasonableness of the sentence, we can, of course, look beyond the reasons stated in the written judgment to consider, as we have in this case, a district court's oral statements of reasons at sentencing as well as the full record of proceedings.
Does the final part of this statement indicate some inclination toward de novo sentencing review?