United States v. Larecius Mattison
685 F. App'x 267
| 4th Cir. | 2017Background
- Defendant Larecius Mattison pled guilty to conspiracy to possess with intent to distribute cocaine and cocaine base.
- At sentencing, the district court held Mattison responsible for at least 1 kilogram of cocaine and imposed a 120-month prison term.
- At the Rule 11 hearing Mattison admitted responsibility for 500 grams or more and agreed the government’s factual recitation was accurate; the factual basis described agents seeing him discard a kilogram wrapper containing a kilogram of cocaine.
- Mattison did not object below to the 1-kilogram attribution, so the Fourth Circuit reviewed that claim for plain error.
- Mattison separately requested placement in a state pre-sentencing drug-treatment program (the Bridge Program); the district court denied the request, citing lack of demonstrated addiction, the seriousness of the offense, and possession of a firearm.
- The Fourth Circuit affirmed, finding no plain error on drug-quantity attribution and that the court adequately addressed the Bridge Program request; the sentence was procedurally and substantively reasonable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court erred in holding Mattison responsible for ≥1 kg cocaine | Mattison contends the court wrongly attributed 1 kg | Government relied on Mattison’s Rule 11 acknowledgments and factual basis describing discarding a 1-kg wrapper | No plain error; admissions at Rule 11 and factual basis support 1-kg attribution |
| Whether court failed to fully consider Mattison’s request for Bridge Program placement | Mattison argues the court did not fully and accurately address his request for pre-sentencing drug-treatment program placement | Court considered relevant factors (evidence of use vs. addiction, offense seriousness, firearm possession) and explained denial | Denial was adequately explained and proper |
Key Cases Cited
- United States v. Gilliam, 987 F.2d 1009 (4th Cir. 1993) (defendant’s Rule 11 acknowledgment can establish drug quantity)
- United States v. Lynn, 592 F.3d 572 (4th Cir. 2010) (standard for plain-error review when issue not raised below)
- United States v. Olano, 507 U.S. 725 (1993) (elements and remedy standards for plain-error review)
- Gall v. United States, 552 U.S. 38 (2007) (standard for reviewing substantive and procedural reasonableness of sentences)