What is the test for reasonableness review when a defendant fails to object to a sentencing error in the Guidelines?

A district court's sentence is subject to reasonableness review, both substantive and procedural. United States v. Cavera, 550 F.3d 180, 190 (2d Cir. 2008) (en banc). "Reasonableness review is similar to review for abuse of discretion and may require reversal when the district court's decision 'cannot be located within the range of permissible decisions' or is based on a legal error or clearly erroneous factual finding." United States v. Villafuerte, 502 F.3d 204, 206 (2d Cir. 2007) (quoting United States v. Sindima, 488 F.3d 81, 85 (2d Cir. 2007)). "A district court commits procedural error where it fails to calculate the Guidelines range" or "makes a mistake in its Guidelines calculation." Cavera, 550 F.3d at 190. When, as here, a

Page 3

defendant fails to object to a purported sentencing error, we review for plain error. Villafuerte, 502 F.3d at 208.