United States v. Williams
2010 U.S. App. LEXIS 26268
1st Cir.2010Background
- Williams was convicted on multiple drug and gun counts arising from a Portland, Maine-based conspiracy.
- He employed intermediaries to purchase guns (straw purchasing) due to his status as a felon.
- A district court appointed a new attorney shortly before trial, prompting a motion to continue.
- The court denied additional continuance after an initial one; trial proceeded and Williams was convicted after a three-day trial.
- Williams challenged the sentence as unreasonable, including drug-quantity calculations, criminal history category, and a downward variance.
- Williams filed a pro se supplemental brief seeking resentencing under the Fair Sentencing Act, which the court treated as premature pending guidelines.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the denial of a four-week continuance was an abuse of discretion | Williams | Williams | No abuse; denial within discretion |
| Whether the trial evidence was insufficient for acquittal | Williams | Williams | Insufficient; defense waived on appeal |
| Whether the drug-quantity calculation supported the base offense level | Williams | Hebert's testimony supported larger quantity | No clear error; quantity reasonable |
| Whether the criminal-history calculations warranted a different category | Williams | Williams | No error; calculations proper |
| Whether the sentence was substantively unreasonable or procedurally flawed under 18 U.S.C. § 3553(a) | Williams | Williams | Sentence reasonable and within district court's discretion |
Key Cases Cited
- United States v. Mangual-Santiago, 562 F.3d 411 (1st Cir. 2009) (standard for abuse of discretion in continuance ruling)
- United States v. Torres, 793 F.2d 436 (1st Cir. 1986) (continuance factors framework)
- United States v. Rodríguez-Durán, 507 F.3d 749 (1st Cir. 2007) (prejudice and continuance analyses guidance)
- United States v. Saccoccia, 58 F.3d 754 (1st Cir. 1995) (prejudice and continuance considerations)
- United States v. Rodriguez-Marrero, 390 F.3d 1 (1st Cir. 2004) (prejudice evaluation in continuance rulings)
- United States v. Hurley, 63 F.3d 1 (1st Cir. 1995) (co-counsel preparation reducing error impact)
- United States v. Bruck, 152 F.3d 40 (1st Cir. 1998) (evidence sufficiency and prejudice related to late-spin evidence)
- United States v. Warshak, F.3d (6th Cir. 2010) (no prejudice from denial of continuance when late evidence)
- United States v. Glover, F. App’x. (2d Cir. 2010) (unpublished; retroactivity considerations in sentencing)