United States v. Lowell, No. 20-2014 (10th Cir. 2021)
Annotate this CaseDaniel Lowell and his girlfriend went on a "Bonnie and Clyde-esque crime spree that turned deadly." While on their way to cash in a stolen car and credit cards, the pair were pulled over outside Las Cruces, New Mexico. A high-speed chase ensued. They carjacked a Toyota 4Runner and eventually law enforcement lost track of them for two and a half hours in Las Cruces, during which time they did drugs and shoplifted items from Walmart that they could use to steal another car. After an officer spotted the 4Runner, another chase ensued, but this time it ended tragically when their car crashed into a motorcyclist, killing him. Lowell pleaded guilty to numerous crimes, including carjacking resulting in death, and was sentenced to 449 months’ imprisonment. On appeal, Lowell challenged the validity of his guilty plea, as well as the district court’s application of the United States Sentencing Guidelines (USSG). Lowell argued his conviction for carjacking resulting in death was invalid because he lacked the specific intent to cause the motorcyclist’s death while in the act of carjacking. According to Lowell, section 2119(3) required "but-for" causation, not specific intent to cause the death. Lowell thus argued the district court erred by applying the first-degree murder cross reference in USSG 2B3.1(c). Finding no reversible error, the Tenth Circuit affirmed Lowell’s conviction and sentence.
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