United States v. Matthew St. Pierre
912 F.3d 1137
| 8th Cir. | 2019Background
- Matthew St. Pierre pled guilty to aiding and abetting second-degree murder of a five-year-old on the Standing Rock Sioux Reservation and agreed in a plea deal that the government would recommend a Guidelines range of 292–365 months.
- The PSR recommended a higher range (360 months to life), adding a § 3C1.1 obstruction-of-justice enhancement; the district court adopted the PSR and applied the enhancement.
- At sentencing the government stated it “adopt[ed]” the amended PSR/addendum but repeatedly requested the court impose the plea-agreement range and joined St. Pierre’s motion for downward departure/variance.
- The district court found St. Pierre’s acceptance of responsibility untimely, applied the obstruction enhancement, adopted the PSR range, and sentenced him to 480 months (within that adopted Guidelines range).
- St. Pierre appealed, arguing the government breached the plea agreement by adopting the PSR addendum and that the district court erred procedurally and substantively in sentencing.
- The Eighth Circuit held the government did not breach the plea agreement, enforced St. Pierre’s appellate waiver, and dismissed the appeal (concluding that, if reached, the sentence would in any event be affirmed).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the government breach the plea agreement by “adopting” the PSR addendum recommending obstruction enhancement? | St. Pierre: govt. adoption amounted to active advocacy for a result inconsistent with its promise to recommend 292–365 months. | Gov’t: it consistently recommended the plea range at sentencing and did not argue for the enhancement; adoption was a neutral statement of the factual record. | No breach; government repeatedly advocated for agreed range and did not actively argue for the enhancement. |
| Is St. Pierre’s appellate waiver valid and enforceable? | St. Pierre: waiver should not bar review of sentencing errors arising from the gov’t conduct and court’s application of Guidelines. | Gov’t: waiver was knowing, voluntary, and covers non-jurisdictional issues like these; no miscarriage of justice. | Waiver valid and enforceable; appeal falls within its scope and was knowingly waived. |
| Did the district court commit significant procedural error in sentencing (e.g., failing to consider disparity)? | St. Pierre: court failed to account for sentencing disparity with similar defendants. | Gov’t/Court: court expressly considered cited comparators and explained differences, including prolonged cruelty. | No procedural error; court showed awareness of § 3553(a) factors and considered disparities. |
| Was the sentence substantively unreasonable or an abuse of discretion? | St. Pierre: court over-weighted certain factors and misapplied Guidelines enhancements. | Gov’t/Court: sentence was within adopted Guidelines range; district court reasonably weighed § 3553(a) factors. | No abuse of discretion; within Guidelines and presumptively reasonable (would be affirmed on merits). |
Key Cases Cited
- Mosley v. United States, 505 F.3d 804 (8th Cir. 2007) (standard of review for plea-agreement interpretation)
- Quebedo v. United States, 788 F.3d 768 (8th Cir. 2015) (appellate-waiver enforcement when government breaches plea agreement)
- Fowler v. United States, 445 F.3d 1035 (8th Cir. 2006) (government breaches by actively advocating outcome inconsistent with plea)
- Thompson v. United States, 403 F.3d 1037 (8th Cir. 2005) (prosecutor’s argument for a different Guidelines application can constitute breach)
- Andis v. United States, 333 F.3d 886 (8th Cir. 2003) (standards for knowing and voluntary appellate-waiver enforcement)
- Gall v. United States, 552 U.S. 38 (2007) (procedural and substantive review framework for sentencing)
- Feemster v. United States, 572 F.3d 455 (8th Cir. 2009) (abuse-of-discretion standard for substantive reasonableness of sentence)