United States v. Lyle Williams
689 F. App'x 810
| 5th Cir. | 2017Background
- Defendant Lyle Eugene Williams pleaded guilty to destruction of mail; guideline range was 9–15 months.
- District court imposed a 36-month sentence after an upward departure/variance, citing U.S.S.G. § 4A1.3 and statutory sentencing objectives.
- The presentence report (PSR) included a factual recitation of a dismissed 1982 homicide charge; the PSR information was from law enforcement sources.
- Williams argued the district court erred by relying on the PSR’s recitation of the dismissed charge, asserting it was an unreliable "bare arrest record."
- Williams also challenged the substantive reasonableness of the 36-month sentence.
- The Fifth Circuit affirmed, holding the PSR’s recitation was sufficiently detailed and reliable and that the upward departure/variance was not unreasonable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court improperly relied on a PSR factual recitation of a dismissed 1982 homicide charge | Williams: PSR entry is a bare arrest record lacking indicia of reliability and cannot support departure/variance | Government/District Court: PSR included detailed factual recitation from law enforcement; not a bare arrest record and was reliable | Affirmed — PSR recitation was sufficiently detailed/reliable; reliance was permissible |
| Whether the 36-month upward departure/variance is substantively unreasonable | Williams: Sentence is greater than justified by the advisory guidelines and facts | Government/District Court: Sentence advances § 3553(a) objectives given Williams’s criminal history and facts; within district court discretion | Affirmed — sentence was reasonable and not an abuse of discretion |
Key Cases Cited
- United States v. Lopez-Velasquez, 526 F.3d 804 (5th Cir.) (prior conduct without conviction may be considered at sentencing)
- United States v. Windless, 719 F.3d 415 (5th Cir.) (distinguishes bare arrest records from arrest entries with reliable factual recitation)
- United States v. Fuentes, 775 F.3d 213 (5th Cir.) (PSR factual recitations from law enforcement can be sufficiently detailed to be reliable)
- Gall v. United States, 552 U.S. 38 (2007) (standard for reviewing substantive reasonableness of sentences)
- United States v. Zuniga-Peralta, 442 F.3d 345 (5th Cir.) (deference to district court sentencing decisions and review of reasonableness)