United States v. Charles Jones
680 F. App'x 451
| 6th Cir. | 2017Background
- Bryant Johnson and Charles Jones pleaded guilty to conspiracy to distribute a substance containing a detectable amount of methamphetamine (21 U.S.C. §§ 841(a)(1), 846) for shipments from Las Vegas to Pulaski County, Kentucky (Nov 2014–May 2015).
- Jones admitted distributing ~300 grams; charged under § 841(b)(1)(B)(viii). PSR produced offense level 23, Criminal History VI, Guidelines 92–115 months; sentenced to 108 months and 4 years supervised release.
- Johnson was held responsible for 311 grams but sentenced under § 841(b)(1)(C). After successful PSR objections (including career-offender issue), his offense level was 23, CHC IV, Guidelines 70–87 months; sentenced to 82 months and 4 years supervised release.
- District court emphasized defendants’ criminal histories, the harms of methamphetamine in Kentucky, and deterrence when imposing sentences above midpoints; both sentences were within Guidelines and no contemporaneous objections were made.
- On appeal both defendants challenged procedural and substantive reasonableness of their within-Guidelines sentences, arguing inadequate consideration of § 3553(a) factors (Johnson: mental health/substance abuse; Jones: individual characteristics and unwarranted disparity with Johnson).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Procedural reasonableness — § 3553(a)(1) consideration | Government: sentencing reviewed for reasonableness; no plain error absent objection | Johnson: court failed to adequately consider his mental-health and substance-abuse history | Court: No plain error; record shows PSR, counsel, and court discussed mental-health and substance-abuse and imposed treatment recommendations |
| Procedural reasonableness — consideration of disparity under § 3553(a)(6) | Government: within-Guidelines sentence satisfies disparity concern | Jones: sentence disparate from Johnson; court failed to address his argument for lower sentence to avoid unwarranted disparity | Court: No plain error; §3553(a)(6) addresses national uniformity and within-Guidelines sentencing and record show court considered disparity arguments |
| Substantive reasonableness — length of sentence | Government: within-Guidelines sentences are presumptively reasonable | Johnson & Jones: their respective sentences were longer than necessary; should have been at bottom of ranges | Court: Affirmed; defendants failed to rebut presumption—court did not arbitrarily or unreasonably weigh factors |
| Plain-error standard of review | Government: failure to object limits review to plain error | Defendants: challenge preserved sufficiency of consideration despite no objection | Court: Applied plain-error framework and found no obvious error affecting substantial rights or fairness |
Key Cases Cited
- Gall v. United States, 552 U.S. 38 (sentences reviewed for reasonableness under abuse-of-discretion standard)
- Vonner v. United States, 516 F.3d 382 (plain-error test for unpreserved sentencing objections)
- Wallace v. United States, 597 F.3d 794 (unpreserved procedural objections reviewed for plain error)
- Coppenger v. United States, 775 F.3d 799 (procedural/substantive reasonableness standards and improper weighing)
- United States v. Pirosko, 787 F.3d 358 (within-Guidelines sentences presumptively substantively reasonable)
- United States v. Carson, 560 F.3d 566 (co-defendant disparity and legitimate reasons for differences)
- United States v. Judge, 649 F.3d 453 (record must show judge aware of and considered defendant's circumstances)