United States v. Susan Williams
699 F. App'x 430
| 5th Cir. | 2017Background
- Susan Williams pleaded guilty to possession with intent to distribute methamphetamine and received a 200-month sentence.
- Williams sought a mitigating-role adjustment under U.S.S.G. § 3B1.2, arguing she was less culpable than average participants.
- The presentence report (PSR) attributed specific drug quantities to Williams based on information from Jonathan Morris and Eric Overstreet.
- At sentencing the court addressed discrepancies in Morris’s prior statements; the government explained them and relied on the PSR figures.
- Williams did not produce rebuttal evidence showing the PSR’s drug-quantity information was materially untrue or unreliable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams was entitled to a § 3B1.2 mitigating-role adjustment | Williams: she played a minor role and lacked planning/decision-making authority | Government: record shows she knowingly transported/distributed meth and was paid for it, demonstrating significant participation | Court: denied adjustment — district court’s factual finding not clearly erroneous; Williams failed to meet burden to prove mitigation |
| Whether PSR drug-quantity information lacked sufficient indicia of reliability | Williams: PSR relied on statements with discrepancies (Morris) and thus is unreliable | Government: discrepancies were explained at hearing; PSR and corroborating testimony provided adequate reliability; Overstreet’s info unrebutted | Court: admitted PSR quantities as reliable; district court did not clearly err in relying on PSR information |
Key Cases Cited
- United States v. Gomez-Valle, 828 F.3d 324 (5th Cir.) (standard: factual findings reviewed for clear error)
- United States v. Betancourt, 422 F.3d 240 (5th Cir.) (district court may rely on PSR for drug-quantity findings)
- United States v. Castro, 843 F.3d 608 (5th Cir.) (defendant bears burden to prove entitlement to role adjustment)
- United States v. Alford, 142 F.3d 825 (5th Cir.) (PSR may provide basis for drug-quantity determination)
- United States v. Valdez, 453 F.3d 252 (5th Cir.) (court may extrapolate drug quantities from reliable evidence, including hearsay)
- United States v. Harris, 702 F.3d 226 (5th Cir.) (PSR has sufficient indicia of reliability absent competent rebuttal)
- United States v. Alaniz, 726 F.3d 586 (5th Cir.) (mere objections to PSR facts are not competent rebuttal evidence)