United States v. Jamie Hunt
2016 U.S. App. LEXIS 19370
| 8th Cir. | 2016Background
- Jamie Lee Hunt pled guilty to conspiracy to distribute 500 grams or more of methamphetamine under 21 U.S.C. § 841(b).
- Police investigations tied a multi-state/mexico conspiracy led by three Ortega brothers; Hunt sold meth on behalf of Salvador Ortega in Minnesota.
- Controlled buys: two ounces on one occasion and four ounces 12 days later; Hunt met with Salvador Ortega after the second buy.
- Plea agreement held Hunt accountable only for the controlled-buy amounts (164.8 grams) but PSR indicated longer involvement (~2.5 years) and connection to large-scale distribution by Salvador Ortega.
- District court calculated a Guidelines range of 130–162 months and sentenced Hunt to 144 months imprisonment.
Issues
| Issue | Plaintiff's Argument (Hunt) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Whether Hunt qualified for a two-level minor-role reduction under U.S.S.G. § 3B1.2 | Hunt argued he was a low-level dealer caught in two controlled buys and less culpable than average participants | Government pointed to Hunt's multi-year involvement, his role selling high-purity meth, contacts to obtain larger quantities, and his association with Salvador Ortega's large distribution | Court affirmed denial: Hunt failed to prove he was substantially less culpable than the average participant; district court's factual findings not clearly erroneous |
| Whether Hunt's 144-month sentence was procedurally or substantively unreasonable | Hunt claimed the court failed to adequately explain the sentence, ignored § 3553(a) factors, and under-weighted mitigating factors (substance abuse, ADHD, disparity with co-defendants, criminal-history exaggeration) | Government maintained the court considered the PSR, heard arguments, referenced § 3553(a) factors, and reasonably rejected Hunt's mitigation claims given his criminal history and role | Court found no procedural error and held the mid-range, within-Guidelines sentence substantively reasonable (no abuse of discretion) |
Key Cases Cited
- United States v. Young, 689 F.3d 941 (8th Cir. 2012) (standard: minor-role is a factual question reviewed for clear error)
- United States v. Gomez-Valle, 828 F.3d 324 (5th Cir. 2016) (Amendment 794 does not guarantee minor-role reduction to everyone below the mastermind)
- United States v. Martin, 757 F.3d 776 (8th Cir. 2014) (two-step review for sentences: procedural then substantive reasonableness)
- Gall v. United States, 552 U.S. 38 (2007) (procedural error examples and requirement to consider § 3553(a) factors)
- United States v. Clayton, 828 F.3d 654 (8th Cir. 2016) (plain-error review when no timely objection at sentencing)
- Feemster v. United States, 572 F.3d 455 (8th Cir. 2009) (district court need not recite § 3553(a) mechanically; record must show consideration)
- United States v. Battiest, 553 F.3d 1132 (8th Cir. 2009) (no procedural error where court examined PSR, heard arguments, and was aware of § 3553(a) factors)
- United States v. Timberlake, 679 F.3d 1008 (8th Cir. 2012) (presumption that court considered and rejected arguments raised in sentencing filings and hearing)
- United States v. San Miguel, 634 F.3d 471 (8th Cir. 2011) (within-Guidelines sentence is presumptively reasonable on appeal)