United States v. Juwan Matthews
2012 U.S. App. LEXIS 24858
| 7th Cir. | 2012Background
- Racine task-force targeted Juwan Matthews for gang/drug activity; Matthews sold 64.5 grams of crack to a confidential informant in five transactions in 2010.
- Matthews was indicted on five counts of distributing crack cocaine, pled guilty to two, and was sentenced to 78 months.
- The presentence report used amended guidelines with the 18:1 crack-to-powder ratio following the Fair Sentencing Act of 2010.
- Matthews urged a 1:1 ratio based on other district cases; prosecutors argued against, citing congressional and commission policy.
- The district court adhered to the 18:1 ratio, rejected a below-guidelines sentence, and imposed 78 months after weighing 3553(a) factors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court treated the 18:1 ratio as mandatory | Matthews argues procedural error from treating the ratio as mandatory | Court exercised discretion but declined to apply 1:1, aligning with Congress/Commission policy | No procedural error; court recognized discretion and adhered to 18:1 ratio |
| Whether the 78-month sentence created unwarranted disparities under §3553(a)(6) | Matthews contends disparities with other Racine cases warrant a lower sentence | Disparities arise from policy disagreements; district court may defer to Congress/Commission | Sentence within guidelines is reasonable; no unwarranted disparity |
Key Cases Cited
- United States v. Booker, 543 U.S. 220 (U.S. (2005)) (upholds discretionary sentencing under Booker/Kimbrough framework)
- Kimbrough v. United States, 552 U.S. 85 (U.S. (2007)) (district courts may vary from guidelines based on policy disagreements)
- Spears v. United States, 555 U.S. 261 (U.S. (2009)) (courts may depart from crack guidelines based on policy judgments)
- Gall v. United States, 552 U.S. 38 (U.S. (2007)) (procedural requirements for considering Guidelines and 3553 factors)
- United States v. Grigsby, 692 F.3d 778 (7th Cir. (2012)) (clarifies discretion and reasonableness review under Booker framework)
- United States v. Carter, 530 F.3d 565 (7th Cir. (2008)) (district courts may respect policy judgments in sentencing)
- United States v. Grigg, 442 F.3d 560 (7th Cir. (2006)) (advocates deference to Congressional/Commission policy in crack sentencing)
- United States v. Boscarino, 437 F.3d 634 (7th Cir. (2006)) (reasonableness of within-guidelines sentence and considering 3553(a)(6))
- United States v. Bartlett, 567 F.3d 901 (7th Cir. (2009)) (within-guidelines sentence presumed reasonable; disparities permissible with justification)
- United States v. Corner, 598 F.3d 411 (7th Cir. (2010)) (en banc noting discretionary departures from guidelines)