United States v. Reid, No. 17-2021 (1st Cir. 2018)Annotate this Case
The First Circuit affirmed the sentenced imposed in connection with Defendant’s guilty plea to possession with intent to distribute, holding that Defendant’s sentence was not substantively unreasonable and that there was no error in the sentence.
After considering a ten-year sentence to protect the public from “someone who is a career criminal,” the court sentenced Defendant to seventy-eight months’ imprisonment, a sentence significantly below Defendant’s guidelines sentencing range as a career offender. The First Circuit affirmed, holding (1) Defendant’s claim that the trial court wrongly denied him a minimal participant reduction was unavailing because a minimal participant designation would not have helped him; (2) Defendant qualified as a career offender; and (3) the below-guidelines sentence of seventy-eight months was not unreasonable.