United States v. Lloyd Meeks
971 F.3d 830
| 8th Cir. | 2020Background
- Meeks was convicted in 2009 of conspiracy to distribute >=50 g cocaine base (originally sentenced to life) and distribution of >=5 g cocaine base (360 months); convictions affirmed on direct appeal.
- At original sentencing the PSR produced an adjusted offense level of 38 and Meeks was treated as a career offender, placing him in Criminal History Category VI.
- Under the First Step Act §404, Meeks moved for a reduced sentence; the district court reduced the conspiracy life sentence to 360 months but left the 360-month distribution sentence unchanged.
- Meeks filed his §404 petition pro se; a local administrative order had authorized the federal public defender to identify and represent eligible defendants, but counsel was not appointed for Meeks during the modification proceeding.
- Meeks appealed, arguing the district court (1) misunderstood its authority to vary below the Guidelines, (2) failed to consider §3553(a) factors, (3) did not perform a complete merits review, and (4) denied his right to counsel.
- The Eighth Circuit affirmed, finding no abuse of discretion and rejecting Meeks’s claims about §3553(a), completeness of review, and entitlement to counsel.
Issues
| Issue | Meeks's Argument | Government's Argument | Held |
|---|---|---|---|
| Whether district court erred by not reducing sentence below the Guidelines / failing to recognize discretion to vary | District court lacked appreciation of its authority to vary and should have reduced sentence below Guidelines | Court had discretion but was not required to vary; Guidelines range governed absent a reasoned basis to go below | Court affirmed: no error—district court properly applied Guidelines and had discretion but need not vary |
| Whether district court had to consider §3553(a) factors in §404 First Step Act review | Court should have applied §3553(a) and addressed those factors | §3553(a) consideration is discretionary in §404 proceedings | Court held consideration of §3553(a) is optional; no error in not addressing them |
| Whether district court failed to perform a "complete review" of Meeks’s motion on the merits | Court did not adequately consider Meeks’s arguments or provide a reasoned basis | Court considered the First Step Act applicability, calculated Guidelines, and explained its decision; Meeks provided no substantive §3553(a) materials | Court held review was complete: Meeks raised only applicability and gave no facts for further mitigation; reasoned basis existed |
| Whether Meeks was entitled to appointed counsel for the §404 resentencing proceeding | Entitled to counsel under the Sixth Amendment or Criminal Justice Act because this was effectively a new sentencing | No constitutional or statutory right to counsel for §3582(c)/§404 proceedings; appointment is discretionary | Court held no constitutional/statutory right to counsel; denial of appointment reviewed for abuse of discretion and was not an abuse |
Key Cases Cited
- United States v. McDonald, 944 F.3d 769 (8th Cir. 2019) (abuse-of-discretion standard for review of sentence-reduction decisions)
- United States v. Moore, 963 F.3d 725 (8th Cir. 2020) (district court may, but need not, consider §3553(a) in §404 proceedings; defines "complete review")
- United States v. Harris, 568 F.3d 666 (8th Cir. 2009) (no Sixth Amendment right to counsel in §3582(c) sentence-modification proceedings)
- United States v. Whitebird, 55 F.3d 1007 (5th Cir. 1995) (sentence-modification motions are vehicles for leniency, not ancillary to initial criminal proceedings)
- United States v. Meeks, 639 F.3d 522 (8th Cir. 2011) (direct-appeal decision affirming convictions and sentence)
- United States v. Tabor, 531 F.3d 688 (8th Cir. 2008) (discussing scope of district court authority at sentencing)