United States v. Maurice Vaughn
2013 U.S. App. LEXIS 13576
| 7th Cir. | 2013Background
- Vaughn and Lockhart were indicted in Aug. 2010 for conspiracy to distribute more than 100 grams of heroin under 21 U.S.C. §§ 841(a)(1), 846; Ford acted as a distributor and intermediary in Beloit, Wisconsin.
- Trial occurred Jan. 2012; jury convicted both defendants largely on circumstantial evidence; Vaughn received 240 months and Lockhart 72 months.
- Vaughn allegedly led a two-shift heroin distribution scheme, directing customers to meet Ford in the morning and Lockhart in the afternoon/evening, with Ford passing proceeds and a cell phone to Vaughn or Lockhart.
- Key witnesses included Ford, Kast (Ford’s girlfriend), and intermediaries like Simms, McShan, Freeman, and others who testified about the two-shift arrangement and role assignments.
- The PSR computed a total drug weight of 1,568.65 grams for Vaughn, with a two-point leadership enhancement; the district court sentenced Vaughn to 240 months and Lockhart to 72 months; both convictions were appealed.
- On appeal, issues included indictment sufficiency and bill of particulars, sufficiency of evidence for the conspiracy, and sentencing challenges to drug weight, criminal history, leadership enhancement, and reasonableness of Vaughn’s within-guidelines sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Indictment sufficiency and bill of particulars | Lockhart argues indictment vague; seeks bill of particulars | Lockhart asserts need for more specific factual allegations | Indictment sufficient; no civil-Twombly/Iqbal standard adopted; bill of particulars denied as non-prejudicial |
| Sufficiency of evidence for conspiracy | Vaughn contends no conspiracy proven beyond reasonable doubt | Ford’s testimony insufficient or impeached; no conspiracy evidence | Sufficient evidence supported conspiracy conviction; Ford’s testimony credible; not a mere buyer-seller relationship |
| Drug weight and relevant conduct | Vaughn challenges reliance on uncharged/pre-conspiracy conduct | Argues double counting and improper averaging of bindles | District court properly applied relevant conduct under §1B1.3; no plain error in drug-weight calculation; no double counting affecting the base offense |
| Leader/organizer enhancement | Leveraged evidence insufficient to show Vaughn controlled others | Argues no supervisory role; misapplied enhancement | Two-level §3B1.1(c) enhancement properly applied based on Vaughn’s control over Ford’s sales |
| Reasonableness of Vaughn’s sentence | Sentence within guidelines is presumptively reasonable | Disparity with co-defendant’s shorter sentence suggests unreasonableness | No procedural error; within-guidelines sentence affirmed as reasonable given Vaughn’s history and role |
Key Cases Cited
- United States v. Smith, 230 F.3d 300 (7th Cir. 2000) (indictment sufficiency standard for criminal charges)
- United States v. White, 610 F.3d 956 (7th Cir. 2010) (indictment and facts sufficiency; elements-based approach)
- Resendiz-Ponce, 549 U.S. 102 (2007) (parroting statute sufficient if not require greater specificity)
- United States v. Singleton, 588 F.3d 497 (7th Cir. 2009) (indictment structure for drug conspiracy under §841(a) and §846)
- United States v. Fassnacht, 332 F.3d 440 (7th Cir. 2003) (bill of particulars sufficiency and notice to prepare defense)