United States v. Matthew Charles
843 F.3d 1142
| 6th Cir. | 2016Background
- Matthew Charles was convicted ~20 years earlier of crack cocaine and related offenses; PSI calculated offense level 38 and CHC VI, recommending 360 months–life and noting he “appears to meet” career-offender and ACCA criteria.
- Charles did not object at sentencing to the career-offender designation; the district court adopted the PSI, varied upward, and sentenced him to 420 months; this court affirmed on direct appeal, holding the district court found him to be a career offender.
- The Sentencing Commission later issued retroactive Amendments 706 and 750 reducing crack-cocaine guideline ranges; Charles filed successive 18 U.S.C. § 3582(c)(2) motions seeking a sentence reduction based on those amendments.
- The government opposed the § 3582(c)(2) motions on the ground that Charles was a career offender and therefore ineligible because the amendments did not lower his applicable guideline range.
- The district court ultimately granted a reduction to 292 months; the government appealed, arguing the reduction was improper because the career-offender finding (as decided on direct appeal) made Charles ineligible for § 3582(c)(2) relief.
Issues
| Issue | Charles' Argument | Government's Argument | Held |
|---|---|---|---|
| Whether Charles is eligible for a § 3582(c)(2) reduction given his career-offender status | The amended crack guidelines lower his range and warrant reduction | He is a career offender as previously determined, so amendments do not lower his applicable range | Court held he is ineligible because prior appellate decision found him a career offender |
| Whether the appellate court’s prior statement that the district court found Charles a career offender binds the district court now (law of the case) | Charles disputed application now and sought reduction despite prior ruling | Prior panel’s finding binds later proceedings under law-of-the-case doctrine | Court applied law of the case and treated the prior finding as binding |
| Whether the government forfeited the career-offender argument by not citing the prior opinion below | Charles argued the government failed to cite the controlling appellate decision and thus forfeited the point | Government repeatedly argued Charles was a career offender in its filings; failure to cite the exact opinion is not forfeiture | Court held no forfeiture—the government sufficiently raised the career-offender objection |
| Proper procedural vehicle to challenge career-offender designation now | Charles contended he is not a career offender and can press that in § 3582(c)(2) proceedings | Such collateral challenges must be pursued via § 2255, not § 3582(c)(2) | Court held § 3582(c)(2) is not the proper vehicle; § 2255 required for merits challenge |
Key Cases Cited
- United States v. Charles, 138 F.3d 257 (6th Cir. 1998) (direct appeal affirming sentence and noting district court found defendant to be a career offender)
- Howe v. City of Akron, 801 F.3d 718 (6th Cir. 2015) (explaining the law-of-the-case doctrine and its exceptions)
- Leonor v. Provident Life & Acc. Co., 790 F.3d 682 (6th Cir. 2015) (failure to cite authority does not automatically forfeit an argument)
- Dixon v. ATI Ladish LLC, 667 F.3d 891 (7th Cir. 2012) (similar principle that omission of a citation does not constitute forfeiture)
- Johnson v. United States, 135 S. Ct. 2551 (2015) (noted as the type of case that would be pursued via § 2255 to challenge career-offender/ACC A-related categorizations)