United States v. Angela Reynolds
703 F. App'x 295
| 5th Cir. | 2017Background
- Reynolds pleaded guilty to conspiring to distribute methamphetamine after agents seized meth from her home and she admitted receiving additional meth from co-defendants.
- The PSR attributed ~1.7 kg of pure methamphetamine to Reynolds based on DPS lab purity estimates applied to seized mixtures and a conversion for HCl form.
- DPS assumed samples that appeared as white/crystalline were methamphetamine HCl and applied a molecular-weight conversion to compute pure-meth amounts; those calculations had a small margin of error.
- The PSR produced an offense level 37 and criminal-history category VI; career-offender status was noted but did not change Reynolds’s Guideline range because the drug offense produced the higher offense level and she was already CHC VI.
- District court imposed a downward departure for cooperation and sentenced Reynolds to 275 months (below the calculated Guideline range capped by the statutory 40-year maximum).
- On appeal, Reynolds supplemented the record with DEA lab reports (from co-defendants’ proceedings) showing those samples were methamphetamine HCl with purities consistent with DPS estimates.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Drug-quantity calculation and use of conversion formula | Reynolds: DPS’s use of an HCl conversion without testing and a margin of error rendered the PSR unreliable and overstated pure-meth weight | Government/DPS: DPS’s methodology is scientifically reasonable; conversion and assumptions are reliable and samples physically appeared as HCl | Affirmed — district court’s drug-quantity finding was plausible; supplemental DEA tests confirmed HCl and purity within DPS margins, keeping amount above 1.5 kg |
| Reliance on PSR estimates with margin of error | Reynolds: small margin of error could produce impossible >100% purities and undermines reliability | Government: small statistical deviations do not show the PSR materially untrue; courts may rely on scientifically acceptable estimates | Affirmed — margin of error alone insufficient to rebut PSR; estimates were scientifically acceptable |
| Whether DPS should have tested form (HCl vs. base) before applying conversion | Reynolds: failure to test means conversion may have overstated weight | Government: experience and physical characteristics reasonably support assuming HCl; DEA reports later confirmed HCl | Affirmed — court need not decide assumption permissibility because supplemental DEA tests confirmed HCl; remand would be futile |
| Career-offender classification impact | Reynolds (post‑Mathis): career-offender status may be invalid, so challenge sentencing enhancement | Government: Reynolds did not preserve this; but career-offender status did not affect Guideline range or sentence here | Affirmed — even if Mathis issue existed, career-offender status did not alter offense level, CHC, or sentence; no relief warranted |
Key Cases Cited
- United States v. Koss, 812 F.3d 460 (5th Cir.) (describing pure-meth weight as controlling for methamphetamine mixtures)
- United States v. Gomez-Alvarez, 781 F.3d 787 (5th Cir. 2015) (clear-error review of sentencing factfindings)
- United States v. Cisneros-Gutierrez, 517 F.3d 751 (5th Cir.) (plausibility standard for district-court factual findings)
- United States v. Nava, 624 F.3d 226 (5th Cir.) (PSR generally bears sufficient indicia of reliability; defendant bears burden to rebut)
- United States v. Sherrod, 964 F.2d 1501 (5th Cir.) (courts may rely on drug-quantity estimates at sentencing)
- United States v. Alford, 142 F.3d 825 (5th Cir.) (district court may rely on estimates absent rebuttal evidence)
- Munoz v. State Farm Lloyds of Texas, 522 F.3d 568 (5th Cir.) (invited‑error doctrine principles cited)
- Mathis v. United States, 136 S. Ct. 2243 (2016) (addressing categorical analysis affecting classification of prior offenses)