United States v. Charles Williamson, 953 F.3d 264

Indicted on multiple drug counts, Williamson pleaded guilty to aiding-and-abetting distribution of methamphetamine; indictment omitted drug weight.
Presentence report attributed most methamphetamine quantity to Williamson based on his accomplice/girlfriend Brea Saeger’s statement that she received ~1 gram/day from Aug 2016–May 2018 (≈630 g).
At sentencing Saeger (who pleaded guilty and cooperated) testified she received ~1 g/day, ~90% as crystal "Ice," sold about $20/day, and used the remainder recreationally; Williamson objected only to counting drugs Saeger consumed personally.
The district court converted to Ice-equivalents, discounted for periods apart, set the base offense level at 32 (150–500 g Ice), applied enhancements/credits, and sentenced Williamson to 121 months.
Williamson appealed arguing (1) drugs Saeger consumed for personal use should not count as relevant conduct for aiding-and-abetting distribution, and (2) the court abused discretion in relying on Saeger’s uncorroborated testimony.

Issue	Williamson's Argument	Government's Argument	Held
Whether drugs distributed to an accomplice for that accomplice's personal use may be counted as relevant conduct in sentencing for aiding-and-abetting distribution	Personal-use quantities received by an accomplice are outside the scope of the offense of conviction and thus should not be included in drug-quantity calculation	Relevant conduct under the Guidelines includes accomplices' conduct; drug-weight scheme requires counting total drugs in the joint enterprise, including amounts an accomplice consumed	Held: No personal-use exception; accomplice's personal-use quantities may be included as relevant conduct for aiding-and-abetting distribution
Whether the district court abused discretion by relying heavily on Saeger’s testimony without corroboration	Saeger was not credible and government failed to corroborate; reliance was unreasonable	District court may credit testimony and uncorroborated hearsay if it has sufficient indicia of reliability; court gave careful adjustments and reductions	Held: No clear error; district court reasonably estimated quantity and credited Saeger's testimony

Kimbrough v. United States, 552 U.S. 85 (explaining Congress’s weight-driven sentencing scheme for drug offenses)
Gall v. United States, 552 U.S. 38 (sentences reviewed for procedural and substantive reasonableness)
United States v. Wyss, 147 F.3d 631 (7th Cir.) (reasoning that an accomplice’s personal use does not change the quantity involved in a conspiracy)
United States v. Innamorati, 996 F.2d 456 (1st Cir.) (treating co-participant purchases for personal use as relevant to conspiracy quantity)
United States v. Bell, 667 F.3d 431 (4th Cir.) (approving district court approaches to estimating drug quantity)
United States v. Wilkinson, 590 F.3d 259 (4th Cir.) (district courts may rely on uncorroborated hearsay at sentencing if sufficiently reliable)
United States v. Randall, 171 F.3d 195 (4th Cir.) (review of drug-quantity findings for clear error)
Callanan v. United States, 364 U.S. 587 (conspiracy law principles treating joint criminal activity as an aggregate enterprise)