United States v. Rentz
696 F. App'x 348
| 10th Cir. | 2017Background
- On January 17, 2015, Rentz drove her car at high speed into oncoming traffic, killing one person and causing life-threatening injuries to another; vehicle data showed 75 mph and 96% accelerator depression with no braking.
- Rentz had been drinking and was on medication she knew should not be mixed with alcohol; her BAC was .19 two hours after the crash; witnesses and family reported she expressed suicidal statements before and after the collision.
- Rentz pled guilty without a plea agreement to involuntary manslaughter (18 U.S.C. § 1112) and assault resulting in serious bodily injury (18 U.S.C. § 113(a)(6)).
- The PSR calculated an advisory Guidelines range of 37–46 months (Offense Level 21, CH I); the Probation Office recommended a two-level upward departure (46–57 months); the government sought 96 months upward based on extreme recklessness/intentional crash.
- The district court found Rentz was suicidal and deliberately crashed her car, concluding her conduct exhibited extreme recklessness nearing intentionality; it imposed an upward variance (six levels) and sentenced her to 84 months.
- On appeal Rentz challenged the substantive reasonableness of the sentence, argued the court improperly relied on her mental/emotional health, and claimed inadequate explanation for rejecting the PSR recommendation; the Tenth Circuit affirmed.
Issues
| Issue | Rentz's Argument | Government/District Court Argument | Held |
|---|---|---|---|
| Whether the upward variance to 84 months was substantively unreasonable | Variance was excessive because her mental health and suicidal state reduced culpability; she lacked intent to harm others | Extreme recklessness (deliberate crash while suicidal) justified a significant variance under § 3553(a) | Affirmed: within range of reasonable outcomes; deferential abuse-of-discretion review supports variance |
| Whether relying on Rentz’s suicidal state was an improper factor | Court improperly increased sentence based on mental/emotional health | Suicidal state was relevant only to show extreme recklessness and deliberate conduct | Rejected: suicidal state was considered only as evidence of extreme recklessness, which supports upward variance |
| Whether the district court failed to explain why it rejected the PSR’s two-level increase / failed to provide written reason | Sentencing explanation was inadequate; PSR recommendation should have been addressed | Record and oral statements provided sufficient reasoning to evaluate substantive reasonableness | Rejected as a basis for reversal; any procedural-explanation issues did not render the sentence substantively unreasonable |
| Whether the district court’s factual finding that Rentz deliberately crashed was clearly erroneous | Challenges finding of purposeful crash and intent to harm others | District court’s factual findings were supported by evidence (statements, vehicle data, witness reports) | Rejected: appellant failed to show clear error; deliberate crash finding stands |
Key Cases Cited
- United States v. Whiteskunk, 162 F.3d 1244 (10th Cir. 1998) (degree of recklessness may justify upward variance beyond heartland of guideline offense)
- United States v. Lente, 759 F.3d 1149 (10th Cir. 2014) (extreme recklessness can support upward variance)
- Gall v. United States, 552 U.S. 38 (2007) (abuse-of-discretion review for substantive reasonableness; give due deference to district court’s § 3553(a) balancing)
- Penry v. Lynaugh, 492 U.S. 302 (1989) (mitigating force of mental/emotional problems on culpability)
- United States v. Reyes-Alfonso, 653 F.3d 1137 (10th Cir. 2011) (sentence must fall within range of possible outcomes supported by facts and law)