United States v. Michael Traylor, Jr., 511 F. App'x 449

Defendant-Appellant Michael C. Traylor, Jr. pled guilty to distributing heroin.
District court calculated 526 kilograms of marijuana equivalency (500 kg cocaine, 426 kg heroin) yielding base offense level 28 and a guideline range of 78–97 months.
Traylor was sentenced within the guideline range to 82 months.
Traylor challenges the 526 kg quantity finding as the basis for the base level.
PSR described drug sales and a video showing Traylor with a brick and a saw allegedly containing cocaine residue.
District court credited the PSR and testimony at sentencing, concluding the quantity evidence supported the 526 kg calculation and the within-guideline sentence was reasonable.]
The appellate court affirmed, holding the district court’s quantity findings were supported by the record and the sentence was not unreasonable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court’s quantity finding is clearly erroneous	Traylor contends the 526 kg figure is not supported.	Traylor argues quantity estimates were improper or underdeveloped.	No clear error; quantity findings supported by preponderance of evidence.
Whether the within-guideline sentence is reasonable	Sentence within range should not be set aside.	District court abused discretion by misapplying quantities	Within-guideline sentence affirmed; abuse-of-discretion standard applied.

United States v. Benson, 591 F.3d 491 (6th Cir. 2010) (preponderance standard for quantity findings; review for clear error)
United States v. Hernandez, 227 F.3d 686 (6th Cir. 2000) (guidelines quantity computation when multiple drugs involved)
United States v. Fletcher, 295 F. App’x 749 (6th Cir. 2008) (quantity estimation permissible when precise amount unknown)
United States v. Walton, 908 F.2d 1289 (6th Cir. 1990) (establishes use of estimates when exact quantity cannot be fixed)
United States v. Bolds, 511 F.3d 568 (6th Cir. 2007) (abuse-of-discretion review for sentencing decisions)