The Sixth Circuit decided a criminal case in which it announced, "We now join several sister circuits [3d, 5th, 7th, 8th] in crediting sentences properly calculated under the Guidelines with a rebuttable presumption of reasonableness." United States v. Williams, No. 05-5416. Once upon a time, in a pre-Booker world, it was believed that the court could not "reverse a sentence imposed under the Guidelines unless based upon a legal or factual error." United States v. Epley, 52 F.3d 571, 580 (6th Cir. 1995). While the biggest change wrought by Booker is greater sentencing freedom for district court judges, it might mean a bit more work at the appellate level, since sentences within the guideline range can conceivably be proved unreasonable.