United States v. Scott Edwards
2016 U.S. App. LEXIS 6748
| 8th Cir. | 2016Background
- Edwards pleaded guilty to one count of felon in possession of a firearm and was sentenced to 108 months after the district court overruled a § 3C1.1 obstruction enhancement, then reduced the term due to an unrelated departure.
- On March 19, 2014, Edwards and Mark Gines were involved in a dispute over paternity and Edwards participated in a shooting at Gines; a high-speed chase followed when Edwards fled the scene.
- Edwards was arrested the same day; police recovered the firearm the next day and DNA from the gun matched Edwards.
- Edwards and Jerome Wilson, also a felon, were indicted for felon in possession of a firearm; Edwards sent two letters to Wilson seeking an alibi and a story about blood on the gun, and Wilson pled guilty afterward.
- At sentencing, the district court calculated an advisory guidelines range of 110–120 months, overruled Edwards's objection to a § 3C1.1 enhancement, and imposed 120 months, later reduced to 108 months; Edwards appeals the guideline calculation and sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper application of § 3C1.1 obstruction enhancement | Edwards argues no prejudice is shown for an obstruction enhancement based on an 'attempt' to influence a witness. | Edwards contends the enhancement applies when conduct constitutes an attempt under the guideline examples, regardless of prejudice. | Enhancement proper; attempt-based conduct falls within § 3C1.1 examples. |
| Substantive reasonableness of 108-month sentence | Court relied too heavily on offense conduct and ignored Edwards's history and rehabilitation prospects. | District court properly weighed § 3553(a) factors and the sentence falls within the guidelines as presumptively reasonable. | Sentence not substantively unreasonable. |
Key Cases Cited
- United States v. Feemster, 572 F.3d 455 (8th Cir. 2009) (procedural error standard for sentencing; reviewing guidelines range)
- United States v. Beckman, 787 F.3d 466 (8th Cir. 2015) (de novo review of Guidelines application)
- United States v. Adejumo, 772 F.3d 513 (8th Cir. 2014) (conduct within 3C1.1 application note 4 examples; prejudice not required for most examples)
- United States v. Sayles, 754 F.3d 564 (8th Cir. 2014) (standard for substantive reasonableness of sentences)
- United States v. Rubashkin, 655 F.3d 849 (8th Cir. 2011) (presumptive reasonableness of within-guidelines sentences)