United States v. Dale Jackson
669 F. App'x 544
| 11th Cir. | 2016Background
- Defendant Dale Jackson, a federal prisoner proceeding pro se, moved under 18 U.S.C. § 3582(c)(2) for a sentence reduction based on Amendment 782 to the Sentencing Guidelines.
- In January 2015 the district court denied relief, stating Jackson was ineligible because a large drug quantity kept his base offense level at 38.
- Jackson sought reconsideration; the district court denied reconsideration in September 2015, finding no grounds to revisit the January ruling.
- Jackson appealed the denial of reconsideration to the Eleventh Circuit, arguing the district court miscalculated his amended Guidelines range and therefore should reconsider relief.
- The government argued Jackson failed to timely appeal the January 2015 order and invoked the law-of-the-case doctrine to bar re-litigation; the Eleventh Circuit considered whether that doctrine applied given alleged clear error.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court erred in calculating Jackson's amended Guidelines range under Amendment 782 | Jackson: his marijuana quantity (75,952.5 kg) yields base offense level 36 under the amended Guidelines | Government: the district court's January ruling (no eligibility) stood and was not timely appealed | Held: January order was plainly erroneous — correct base level is 36, not 38; miscalculation was plain error |
| Whether the law-of-the-case doctrine bars reconsideration of the January 2015 ruling | Jackson: court should reconsider because the January ruling was clearly erroneous and causes manifest injustice | Government: law of the case applies; Jackson had opportunity to appeal the January order but did not | Held: Law of the case does not bar reconsideration because the earlier decision was clearly erroneous and would cause manifest injustice |
| Whether Jackson's substantial rights and fundamental fairness were affected by the Guidelines error | Jackson: incorrect Guidelines range deprived the court of proper guidance under § 3582(c)(2) and § 3553(a) | Government: (implicit) any error did not justify reconsideration given procedural posture | Held: Error affected substantial rights and fairness; guidelines errors can be particularly serious and may affect sentencing determination |
| Whether the district court abused its discretion in denying reconsideration | Jackson: district court relied on the erroneous January conclusion and thus abused discretion | Government: denial was appropriate because no grounds for reconsideration were shown | Held: District court abused its discretion; Eleventh Circuit vacated and remanded for reconsideration in light of correct Guidelines and § 3553(a) factors |
Key Cases Cited
- United States v. Escobar-Urrego, 110 F.3d 1556 (11th Cir. 1997) (law-of-the-case doctrine exceptions where decision is clearly erroneous and would cause manifest injustice)
- United States v. Quintana, 300 F.3d 1227 (11th Cir. 2002) (explaining manifest injustice equals plain error standard)
- United States v. Bravo, 203 F.3d 778 (11th Cir. 2000) (district court must recalculate guideline range when considering a § 3582(c)(2) motion)
- United States v. Bennett, 472 F.3d 825 (11th Cir. 2006) (miscalculation of offense level can be plain error)
- Molina-Martinez v. United States, 136 S. Ct. 1338 (2016) (defendant may show substantial-rights effect from incorrect Guidelines range even if sentence falls within both ranges)
- United States v. Izquierdo, 448 F.3d 1269 (11th Cir. 2006) (abuse-of-discretion standard when district court fails to apply correct legal standard)
- United States v. Webb, 565 F.3d 789 (11th Cir. 2009) (courts liberally construe pro se pleadings)
- United States v. Simms, 385 F.3d 1347 (11th Cir. 2004) (standard of review for denial of reconsideration in criminal cases)