United States v. Maurice Sayles
754 F.3d 564
| 8th Cir. | 2014Background
- Twin brothers Martinus and Maurice Sayles pled guilty to conspiracy to commit wire fraud; they stole checks, forged checks, purchased and then redeemed merchandise for cash; loss attributable to the scheme was $5,990; indictment filed April 4, 2012 in Western District of Missouri; Martinus pled guilty without a written plea agreement; Maurice pled guilty under a written plea agreement; district court sentenced Martinus to 85 months and Maurice to 85 months after a variance.
- Maurice’s plea agreement prevented a higher-than-guidelines sentence, but the government breached the agreement and sought a sentence at least as long as Martinus’s; Maurice had a leadership role in the conspiracy and a criminal history similar to Martinus, justifying upward variance.
- The district court varied upward from the guidelines range for each defendant due to serious nature of the crime, Maurice’s leadership role, and criminal history; the court emphasized the brothers’ equal culpability.
- The appellate court applies an abuse-of-discretion standard for substantive reasonableness and plain-error review for unraised issues; the court found the variances justified and adequately explained; the sentences were affirmed.
- The court noted the criminal history points were capped by the guideline limits and found substantial justification for any variance, affirming both sentences.
- The opinions record the district court’s consideration of § 3553(a) factors and reaffirm the superior position of the trial judge to assess case-specific facts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the sentences are substantively reasonable | Martinus argues the sentence is unreasonable | Martinus must show the district court erred, but court properly weighed factors | No; sentences reasonable given factors & justification |
| Whether the government breach of the plea agreement affected Maurice’s sentence | Maurice argues breach invalidates waiver and affected sentence | Court would have varied upward regardless; breach did not affect due process | No plain-error impact; breach not shown to affect sentence |
| Procedural challenges to Maurice’s sentence calculation | Maurice contends miscalculation or misapplication of § 3B1.1(b) | Court correctly applied enhancement for leadership | No plain error; district court properly explained rationale |
| Whether the district court’s variance from the guidelines was justified | Government advocated high-end or above-range sentence | Variance supported by serious history and leadership role | Yes, adequately justified under § 3553(a) and Hill |
Key Cases Cited
- United States v. VandeBrake, 679 F.3d 1030 (8th Cir. 2012) (abuse-of-discretion standard for substantive reasonableness)
- United States v. Smith, 573 F.3d 639 (8th Cir. 2009) (plain-error review for unraised issues)
- United States v. Burnette, 518 F.3d 942 (8th Cir. 2008) (plain-error standard guidance)
- United States v. Pirani, 406 F.3d 543 (8th Cir. 2005) (en banc; due-process impact of breach)
- United States v. Plaza, 471 F.3d 876 (8th Cir. 2006) (variance justification proportional to deviation from Guidelines)
- United States v. Hill, 552 F.3d 686 (8th Cir. 2009) (upholding above-range sentence with adequate explanation)
- Booker v. United States, 543 U.S. 220 (U.S. 2005) (guidelines considerations with § 3553(a))
- Johnson v. United States, 520 U.S. 461 (U.S. 1997) (plain-error standard guidance)