Brief of Amicus Curiae the National Association of Criminal Defense Lawyers in Support of Defendant/Appellant and Reversal.
Argument: Allocution affects sentencing in significant, unpredictable ways. Complete denial of the right to allocute necessitates reversal of the sentence. Complete denial of the allocution right satisfies the third and fourth prongs of the plain error test. The exceptions to this rule are highly limited. No proffer is required.