United States v. Williams
788 F. Supp. 2d 847
N.D. Iowa2011Background
- Williams pled guilty to four crack cocaine offenses; sentencing framed around whether to apply the 18:1 crack-to-powder ratio or maintain the 1:1 ratio; the 2010 Fair Sentencing Act and emergency guidelines amendments established an 18:1 ratio; the government urged adopting 18:1 with typical sentences within the new guidelines; defense urged maintaining 1:1 and variancing under 18 U.S.C. §3553(a); the court previously adopted 1:1 in Gully and Spears, and weighed the new 18:1 against its prior reasoning; the court ultimately rejects the 18:1 ratio and adopts a methodology using 1:1 with case-specific adjustments and 3553(a) factors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to adopt the 18:1 ratio for Williams' sentence | Prosecution supports 18:1 as congressional and Commission policy | Williams and amicus argue 18:1 rests on compromised, non-empirical rationales | No; the court rejects the 18:1 ratio on policy grounds |
| Whether the 2010 amendments justify abandoning 1:1 | 19:1 ratio reflects congressional intent and Commission guidance | Legislative history shows compromise, not substantiation; still supports 1:1 methodology | No; amendments do not justify abandoning 1:1 approach |
| What sentencing methodology should govern crack offenses | Sentence within 18:1 range; align with guidelines | Use 1:1 as baseline; adjust based on §3553(a) factors | Adopt 1:1 baseline with case-specific 3553(a) adjustments; avoid using 18:1 as a fixed proxy |
| Do concerns about racial impact support keeping 18:1 | 18:1 reduces disparity | Disparity persists; 18:1 still unfair; not a cure | Reject final reliance on 18:1 as sole basis for sentence |
| Is Pepper v. United States applicable to justify policy-based variance | Pepper supports discretion to reject Guidelines on policy grounds | Gully/Whigham limit scope; variance must be grounded in §3553(a) factors | Pepper supports discretion; court still uses 1:1 with 3553(a) factors |
Key Cases Cited
- Kimbrough v. United States, 552 U.S. 85 (U.S. 2007) (advisory Guidelines; policy disagreements permissible to vary from guidelines)
- Spears v. United States, 555 U.S. 261 (U.S. 2009) (district courts may reject crack/powder disparity on policy grounds)
- United States v. Gully, 619 F. Supp. 2d 633 (N.D. Iowa 2009) (rejected 100:1; proposed 1:1 baseline with 3553(a) adjustments)
- Pepper v. United States, 131 S. Ct. 1229 (S. Ct. 2011) (supports discretion to reject guidelines on policy grounds)
- Whigham v. United States, 754 F. Supp. 2d 239 (D. Mass. 2010) (adopted 1:1 ratio in post-2010 amendments context)
- United States v. Robinson, 462 F.3d 824 (8th Cir. 2006) (discusses convertibility of cocaine forms and ratio concerns)