United States v. Batts, No. 13-3796 (8th Cir. 2014)
Annotate this Case
Justia Opinion Summary
Want to stay in the know about new opinions from the Eighth Circuit U.S. Court of Appeals?
Sign up for free summaries delivered directly to your inbox. Learn More ›
You already receive new opinion summaries from Eighth Circuit U.S. Court of Appeals. Did you know we offer summary newsletters for even more practice areas and jurisdictions? Explore them here.
Defendant walked away from a prison camp at the Federal Correctional Institution (FCI) and a federal magistrate judge issued a warrant for his arrest. Defendant pled guilty to one count of escape of a prisoner in custody in violation of 18 U.S.C. 751(a). The court concluded that the district court did not err in denying defendant's request for a four-level reduction to his base offense level under U.S.S.G. 2P1.1(b)(3) where the reduction does not apply to defendants who escape from a prison camp because prison camps are not similar to the institutions described by section 2P1.1(b)(3). Accordingly, the court affirmed the judgment of the district court.
Court Description: Criminal case - Sentencing. Prison camps are not similar to the institutions described in Guidelines Sec. 2P1.1(b)(3), and defendant, who walked away from his prison camp, was not entitled to the reduction set out in the section. [ July 09, 2014
Download PDF
United States Court of Appeals For the Eighth Circuit ___________________________ No. 13-3796 ___________________________ United States of America lllllllllllllllllllll Plaintiff - Appellee v. Adrian Batts lllllllllllllllllllll Defendant - Appellant ____________ Appeal from United States District Court for the Eastern District of Arkansas - Little Rock ____________ Submitted: May 23, 2014 Filed: July 10, 2014 [Published] ____________ Before BYE, COLLOTON, and GRUENDER, Circuit Judges. ____________ PER CURIAM. Adrian Batts walked away from the prison camp at the Federal Correctional Institution ( FCI ) in Forrest City, Arkansas. A federal magistrate judge issued a warrant for his arrest, and the United States Marshals Service apprehended Batts approximately one month after his escape from the camp. Batts pled guilty to one count of escape of a prisoner in custody, in violation of 18 U.S.C. § 751(a). At sentencing, Batts argued that he was entitled to a four-level reduction to his base offense level under USSG § 2P1.1(b)(3). The district court1 denied Batts s request for a reduction and sentenced him to 24 months imprisonment.2 This appeal followed, and we affirm. [A] district court s interpretation and application of the guidelines is reviewed de novo and its factual findings are reviewed for clear error. United States v. Dengler, 695 F.3d 736, 739 (8th Cir. 2012). As relevant here, the sentencing guidelines provide for a four-level reduction to the base offense level where the defendant escaped from the non-secure custody of a community corrections center, community treatment center, halfway house, or similar facility. USSG § 2P1.1(b)(3). At sentencing, the defendant bears the burden to prove that he is entitled to a reduction under § 2P1.1(b)(3). United States v. Love, 74 F.3d 1244, at *1 (8th Cir. 1996) (unpublished per curiam); see also United States v. Stavig, 80 F.3d 1241, 1245 (8th Cir. 1996) (holding that defendant bears burden to prove mitigating factors at sentencing). On appeal, Batts s sole argument is that a prison camp, such as the one at FCI, is a non-secure facility similar to a community corrections center, community treatment center, or halfway house. Although our court has not yet addressed this question, several of our sister circuits have. Without exception, they have determined that prison camps are not similar to the institutions described in § 2P1.1(b)(3) and that the reduction therefore does not apply to defendants who escape from a prison camp. See United States v. McCullough, 53 F.3d 164, 165 (6th Cir. 1995); United States v. 1 The Honorable James M. Moody, Sr., United States District Judge for the Eastern District of Arkansas. 2 At sentencing, Batts also raised an argument involving USSG § 2P1.1(b)(2). However, Batts abandoned this argument on appeal relying only on § 2P1.1(b)(3) in his brief. See United States v. Arnold, 725 F.3d 896, 897 n.2 (8th Cir. 2013). -2- Stalbaum, 63 F.3d 537, 540 (7th Cir. 1995); United States v. Hillstrom, 988 F.2d 448 (3d Cir. 1993) (remanding for further consideration to determine whether a prison camp is a similar facility ), on remand, 837 F. Supp. 1324, 1339 (M.D. Pa. 1993) (deciding on remand that a prison camp is not a similar facility ), aff d without op., 37 F.3d 1490 (3d Cir. 1994); United States v. Tapia, 981 F.2d 1194, 1197-98 (11th Cir. 1993); United States v. Shaw, 979 F.2d 41, 44-45 (5th Cir. 1992); United States v. Brownlee, 970 F.2d 764, 765 (10th Cir. 1992); United States v. McGann, 960 F.2d 846, 847 (9th Cir. 1992). We agree, in particular, with the Tenth Circuit s rationale in distinguishing prison camps from the institutions listed in § 2P1.1(b)(3): The facilities listed in the guideline are all integrated into the community. A prison camp, even though there may be no perimeter barriers and residents may have some freedom to come and go, is an environment separated from the community. Further, prison camps were recognized institutions in the corrections system long before the enactment of the sentencing guidelines and, had the Sentencing Commission intended that prison camps be within the purview of § 2P1.1(b)(3), it could have included them specifically. Brownlee, 970 F.2d at 765. Accordingly, the district court did not err in denying Batts s request for a reduction under § 2P1.1(b)(3), and we affirm the sentence.3 ______________________________ 3 Batts does not challenge the substantive reasonableness of his sentence. Thus, we do not address that issue. See United States v. Brown, 550 F.3d 724, 729 n. 4 (8th Cir. 2008). -3-
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.
