United States v. Martise Chatman
2015 U.S. App. LEXIS 19505
| 7th Cir. | 2015Background
- Chatman pleaded guilty to one count of heroin distribution; district court sentenced him to 160 months' imprisonment and three years' supervised release.
- Presentence report showed 15 prior convictions (including two possession, two DUI, three delivery convictions, one unlawful-weapon-by-felon, one domestic battery, multiple license violations), yielding 27 criminal-history points and Guideline Category VI.
- At sentencing the government characterized Chatman as having “several” DUIs and possession convictions; Chatman contended “several” implied more than two and argued the court would have used Category V if corrected.
- The district court imposed supervised-release conditions including limits on “excessive” alcohol use (defined as more than four drinks/day orally), prohibition on unlawful or non-prescribed controlled-substance use, and a mental-health evaluation; written conditions included an extra mental-health evaluation during BOP custody.
- Chatman appealed arguing (1) the government’s imprecise description of his record led to a clearly erroneous reliance at sentencing, and (2) certain supervised-release conditions were vague or inconsistent (notably the extra mental-health evaluation).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether government’s oral description of prior convictions rendered sentencing based on clearly erroneous facts | Chatman: government’s use of “several” mischaracterized his two DUIs and two possession convictions and caused court to err (should be Cat V) | Government/District Court: record (PSR, memoranda, calculations) supported Category VI; court did not rely on the imprecise phrasing | No plain error; Category VI supported by PSR and 27 points; court did not actually rely on the imprecise oral description |
| Whether alcohol-condition (“excessive use”) is unconstitutionally vague | Chatman: “drinks” undefined so condition vague | Court: defined quantity orally (more than four drinks/day); reasonable person can understand what a drink is | Condition sufficiently definite; not vague |
| Whether controlled-substance condition is ambiguous or conflicts between oral and written pronouncements | Chatman: oral phrase “refrain from excessive use” ambiguous; written order appears stricter or inconsistent | Government: written order clarifies oral statement to prohibit unlawful/non-prescribed use, resolving ambiguity | Upheld: written condition clarifies oral pronouncement and controls when consistent; prohibition on unlawful/non-prescribed use stands |
| Whether requiring two mental-health evaluations (one during BOP custody) was valid | Chatman: oral pronouncement required only one evaluation; written order added a second unpronounced evaluation (contradiction) | Government: acknowledged inconsistency but argued harmless | Court: written unpronounced second evaluation contradicted unambiguous oral pronouncement, so expunge the BOP-custody evaluation; modification is harmless and no remand required |
Key Cases Cited
- United States v. Corona-Gonzalez, 628 F.3d 336 (7th Cir.) (error occurs when sentence is based on clearly erroneous facts)
- Gall v. United States, 552 U.S. 38 (Supreme Court) (procedural error standards for sentencing)
- United States v. Durham, 645 F.3d 883 (7th Cir.) (plain-error reversal where court relied on nonexistent violent-history facts)
- United States v. Kappes, 782 F.3d 828 (7th Cir.) (standards for supervised-release conditions; oral pronouncement controls unless written clarification consistent)
- United States v. Siegel, 753 F.3d 705 (7th Cir.) (vagueness limits on supervised-release alcohol conditions; suggested concrete definitions)
- United States v. Adkins, 743 F.3d 176 (7th Cir.) (deference to district court on tailored supervised-release conditions)
- United States v. Boyd, 608 F.3d 331 (7th Cir.) (authority for modifying/expunging inconsistent supervised-release condition without remand)