United States v. Chapman, No. 17-1656 (3d Cir. 2019)Annotate this Case
In 2016, Chapman pled guilty to conspiracy to possess with the intent to distribute cocaine. After several continuances, the district court set a date for Chapman’s sentencing hearing. On the scheduled date, Chapman immediately informed the court that he was never told of the hearing due to his counsel’s error and had been unable to notify his family of his sentencing. He requested a continuance so that his family could be present and provide letters of support. The district court acknowledged that defense counsel’s error caused Chapman’s lack of notice but denied the request, stating that proceeding with the sentencing as scheduled would not impact his substantive rights. The Third Circuit vacated the sentence. The ruling constituted an abuse of discretion because it interfered with Chapman’s right to allocution as codified in the Federal Rule of Criminal Procedure 32(i)(4)(A), which allows a defendant to present any information that could persuade a court to impose a lesser sentence.