United States v. Johnson
23-30877
5th Cir.Apr 14, 2025Background
- Arisa Johnson pleaded guilty to conspiracy to possess with intent to distribute methamphetamine in violation of federal law.
- Johnson was sentenced to 168 months in prison, a sentence within the Guidelines.
- The district court applied a two-level aggravating-role enhancement, finding Johnson to be an organizer, leader, manager, or supervisor under Sentencing Guideline § 3B1.1(c).
- Johnson appealed, arguing the enhancement was not justified by the facts of the case.
- The government argued that Johnson's objection to the enhancement was not preserved but the Fifth Circuit chose to assume the issue was preserved.
- The appellate court reviewed the district court's factual findings for clear error.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Aggravating-role enhancement under §3B1.1(c) | Johnson's actions justified enhancement | Insufficient evidence Johnson was a leader | Enhancement properly applied |
| Standard of review | Factual findings should be upheld absent clear error | District Court erred in applying the facts | No clear error on the record |
| Preservation of objection | Issue possibly not preserved below | Issue adequately preserved | Court assumes preservation |
| Sentencing Guideline calculation error | Guidelines were accurately calculated | Guideline application was procedural error | No calculation error |
Key Cases Cited
- Gall v. United States, 552 U.S. 38 (procedural and substantive reasonableness review after Booker)
- United States v. Delgado-Martinez, 564 F.3d 750 (abuse-of-discretion standard for sentence reasonableness)
- United States v. Cisneros-Gutierrez, 517 F.3d 751 (standards of review for sentencing issues)
- United States v. Ochoa-Gomez, 777 F.3d 278 (factors for leadership enhancement under the Guidelines)
- United States v. Guzman-Reyes, 853 F.3d 260 (applies management responsibility principle in sentencing)