The Supreme Court has held that appellate courts must apply a deferential abuse of discretion standard in reviewing all sentences, whether within or outside the Guidelines. The Court rejects an appellate rule that requires “extraordinary circumstances” to justify a non-Guideline sentence. Gall v. United States, 2007 WL 4292116 (U.S. Dec. 10, 2007). Further, the Court holds that the crack Guideline is likewise advisory and therefore the sentencing court’s conclusion that Guideline sentence was unduly harsh was reasonable. Kimbrough v. United States, 2007 WL 4292040 (U.S. Dec. 10, 2007).