United States v. Matthew Rutledge
669 F. App'x 265
5th Cir.2016Background
- Matthew Rutledge pleaded guilty to conspiracy to possess with intent to distribute 50 grams or more of a methamphetamine mixture, in violation of 21 U.S.C. §§ 841, 846.
- The PSR attributed a drug-quantity to Rutledge that produced an advisory Guidelines range; the district court sentenced him to 324 months (at the bottom of that range).
- Rutledge objected, arguing the PSR’s drug-quantity finding was not sufficiently specific or reliable to support the Guidelines calculation.
- He submitted a letter from one co-defendant claiming that co-defendant’s statements did not implicate Rutledge; he otherwise offered no rebuttal evidence to the PSR’s account.
- At sentencing the district court considered and overruled Rutledge’s objections, finding the PSR reliable based on statements from multiple co-conspirators and other information.
- Rutledge appealed, challenging the drug-quantity determination and alleging noncompliance with Fed. R. Crim. P. 32(i)(3)(B).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency/reliability of PSR drug-quantity finding | Rutledge: PSR not sufficiently specific or reliable to attribute drug quantity to him | Government: PSR is reliable; multiple co-conspirators and other information support quantity | Court: Upheld drug-quantity finding — plausible on record; defendant failed to present rebuttal evidence showing PSR unreliable |
| Standard of review for Guidelines calculation | Rutledge: (implicit) district erred in factfinding | Government: district properly applied Guidelines and resolved objections | Court: Legal application of Guidelines reviewed de novo; factual findings for clear error; here factual finding not clearly erroneous |
| Compliance with Rule 32(i)(3)(B) | Rutledge: district court failed to resolve and rule on disputed PSR portions | Government: court explicitly addressed and overruled objections at sentencing | Court: Rutledge’s Rule 32 claim unsupported — court explicitly ruled on objections |
| Burden to rebut PSR | Rutledge: PSR unreliable based on one co-defendant’s letter | Government: defendant bears burden to present rebuttal evidence | Court: Defendant failed to carry burden; conclusory assertions insufficient |
Key Cases Cited
- Gall v. United States, 552 U.S. 38 (establishes procedural framework for post-Booker sentencing review and reasonableness standard)
- United States v. Cisneros-Gutierrez, 517 F.3d 751 (explains de novo review of guideline application and clear-error review of factual findings)
- United States v. Betancourt, 422 F.3d 240 (drug-quantity findings reviewed for clear error and upheld if plausible in light of record)
- United States v. Alford, 142 F.3d 825 (PSR may provide reliable basis for sentencing drug-quantity determinations)
- United States v. Harris, 702 F.3d 226 (defendant bears burden to present rebuttal evidence demonstrating PSR information is unreliable)