United States v. Christopher DeShaun Young
671 F. App'x 754
| 11th Cir. | 2016Background
- Christopher Young pleaded guilty to conspiracy to distribute controlled substances (21 U.S.C. § 846) and possessing a firearm in furtherance of a drug-trafficking crime (18 U.S.C. § 924(c)(1)(A)).
- Plea agreement included a government promise to recommend a sentence within the Sentencing Guidelines range (210–240 months, plus a mandatory consecutive 60 months).
- Before sentencing, the government alleged Young obstructed justice by threatening codefendants to stay silent and not cooperate.
- The government presented recorded calls, an FBI agent’s testimony, and testimony from a threatened co-defendant at a hearing.
- The district court found by a preponderance of the evidence that Young obstructed justice, concluding he breached the plea agreement and releasing the government from its recommendation obligation.
- Young appealed, arguing the government breached the plea agreement by not recommending a within-guidelines sentence and that the government failed to prove his obstruction conduct.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether gov't breached plea agreement by not recommending a within-Guidelines sentence | Gov't breached by failing to recommend within-range | Gov't contends it was released from obligation after Young breached | Affirmed: even if unclear, gov't was released after Young’s breach |
| Whether Young obstructed justice by threatening witnesses | Young: gov't did not prove obstruction | Gov't: recordings and testimony show threats and tampering | District court’s finding of obstruction upheld (not clearly erroneous) |
| Standard of review for plea-breach claim | — | — | Legal question reviewed de novo; factual findings reviewed for clear error |
| Whether gov't’s request for a “substantial period of incarceration” conflicted with its obligation | Young: inconsistent with promise to recommend within-range | Gov't: request not clearly inconsistent and district court did not construe it as seeking above-range | Court noted no clear inconsistency; district court’s construction controls |
Key Cases Cited
- United States v. Horsfall, 552 F.3d 1275 (11th Cir. 2008) (government bound by material plea promises)
- United States v. Amedeo, 370 F.3d 1305 (11th Cir. 2004) (factual findings on conduct reviewed for clear error)
- United States v. Jenkins, 901 F.2d 1075 (11th Cir. 1990) (deference to district court credibility determinations)
- United States v. Salmona, 810 F.3d 806 (11th Cir. 2016) (defendant’s substantial breach releases government from plea obligations)