United States v. Miller, No. 11-3701 (8th Cir. 2012)
Annotate this CaseDefendant, husband and wife, were convicted of drug related charges. The court held that the evidence was sufficient to prove beyond a reasonable doubt that wife aided and abetted the distribution of methamphetamine and conspiracy to distribute 50 grams or more of a mixture containing methamphetamine; the district court did not abuse its discretion by denying part of husband's discovery motion; and the district court did not commit procedural sentencing error by imposing a two-level increase under U.S.S.G. 2D1.1(b)(12). The court held, however, that even under plain error review, the district court's failure to apply amended U.S.S.G. 2D1.1(a)(5) resulted in an erroneous application of the Guidelines that could have substantially increased wife's advisory guidelines range. Accordingly, the court affirmed husband's conviction and sentence; affirmed wife's conviction; but vacated wife's sentence and remanded for resentencing.
Court Description: Criminal case - Criminal law. Evidence was sufficient to support defendant Rebecca Miller's conviction for conspiracy and for aiding and abetting the distribution of methamphetamine; no Brady violation shown concerning information regarding cooperating witness; defendant failed to make the showing of special need required to gain access to other defendants' PSRs; no error in imposing an enhancement under Guidelines Sec. 2D1.1(b)(12) for maintaining a crack house; Rebecca Miller's sentence is vacated and her case is remanded for further proceedings as the district court erred in failing to consider the application of Guidelines Sec. 2D1.1(a)(5) and in calculating the drug quantity.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.