United States v. M.M., No. 20-2788 (3d Cir. 2022)
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In 2017, a man was found dead next to 22 small wax bags containing fentanyl-laced heroin, stamped “WI FIGHT?” He had overdosed on fentanyl and heroin. Officers determined that M.M. was the victim’s drug dealer. Charged with intent to distribute a controlled substance, 21 U.S.C. 841(a)(1), and distribution of a controlled substance resulting in death, section 841(b)(1)(C), M.M. entered into a plea agreement. Pursuant to 18 U.S.C. 3553(e), the government recommended a departure below the applicable mandatory minimum sentence of 240 months if M.M. provided “substantial assistance.”
M.M. invoked section 3553(a)'s factors, including his addiction and psychological issues related to his upbringing. The court granted the downward departure motion after evaluating M.M.’s cooperation and addressing those factors but without specifying the basis of the departure. The government challenged the 120-month sentence under Rule 35(a), arguing that section 3553(e) does not allow a court to reduce a sentence below a statutory mandatory minimum based on considerations unrelated to substantial assistance. The District Court agreed that clear error had occurred and clarified that M.M.’s substantial assistance entitled him to a departure to 180 months’ imprisonment. The Third Circuit vacated. The authority to amend a sentence under Rule 35(a) is very narrow and there was no clear error in the original sentence.
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