United States v. Donald Margus Young
692 F. App'x 595
| 11th Cir. | 2017Background
- Defendant Donald Young pleaded guilty to conspiracy to distribute 28 grams or more of cocaine base and was sentenced to 84 months’ imprisonment.
- At sentencing the district court attributed to Young only 84 grams of crack cocaine (his admitted involvement), not a larger Latin Kings conspiracy.
- Young sought a mitigating-role adjustment under U.S.S.G. § 3B1.2, arguing his relevant conduct was minor compared to a larger related conspiracy.
- The presentence facts showed Young bought powder cocaine, converted it to crack, insisted on quality and ‘‘cooked’’ the cocaine himself, and paid high prices and sustained losses—indicating knowledge, authority, and profit motive.
- Young had an extensive criminal history (Criminal History Category VI) including violent and firearms convictions; some convictions that would have added points were not counted because of the scoring cap.
- The district court denied the role reduction and imposed an 84-month sentence (low end of the 84–105 month advisory Guidelines range). Young appealed, challenging the role adjustment denial and the substantive reasonableness of his sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Young was entitled to a minor/mitigating-role reduction under U.S.S.G. § 3B1.2 | Young: his relevant conduct should reflect the larger Latin Kings conspiracy and thus he was a minor participant | Government/District Court: relevant conduct was limited to the 84 grams Young admitted; his actual role showed authority and profit motive, not minor participation | Court affirmed: no clear error in denying role reduction; relevant conduct equals attributed conduct and facts show more than a minor role |
| Whether the 84-month sentence was substantively unreasonable | Young: 84 months (despite being within Guidelines) was excessive given his role and mitigating factors | Government/District Court: 84 months is low end of Guidelines, accounts for serious conduct and extensive criminal history; district court reasonably weighed § 3553(a) factors | Court affirmed: sentence was not substantively unreasonable; no abuse of discretion |
Key Cases Cited
- United States v. De Varon, 175 F.3d 930 (11th Cir.) (en banc) (role-of-defendant review standard and comparison to relevant conduct)
- United States v. Alvarez-Coria, 447 F.3d 1340 (11th Cir. 2006) (defendant cannot obtain role reduction by pointing to larger conspiracy for which he was not held accountable)
- United States v. Cubero, 754 F.3d 888 (11th Cir. 2014) (two-step abuse-of-discretion standard for reviewing sentence reasonableness)
- United States v. Asante, 782 F.3d 639 (11th Cir. 2015) (burden on challenger to show sentence is substantively unreasonable)
- United States v. Williams, 526 F.3d 1312 (11th Cir. 2008) (district court has discretion in weighting § 3553(a) factors)