United States v. Mercado, No. 09-1283-cr (2d Cir. March 25, 2010) (found here)
Among other things, Mercado argued that the district court erred in sentencing him for a supervised release violation because it failed to articulate its reasons for the sentence imposed. And the Second Circuit agreed -- sort-of.
Specifically, it found that "the district court, in imposing a one-year term of imprisonment, did not explain its reasons for doing so except to note that this was the term recommended by the Probation Office." However, as the Second Circuit explained in United States v. Espinoza, 514 F.3d 209, 212 (2d Cir. 2008) (per curium):
Establishing that a sentencing court failed to fulfil the "open court" requirement is not . . . tantamount to plain error. . . . [F]ailure to satisfy the open court requirement of § 3553(c) . . . does not constitute "plain error" if the district court relies on the PSR, and the factual findings in the PSR are adequate to support the sentence.
The rule applies equally to sentencing for violations of supervised release.
The lesson to learn is to examine sentencing transcripts carefully on appeal. If no mention is made of the reason for the sentence imposed, it might well prove fertile ground for appeal.