United States v. Williams, No. 20-4002 (4th Cir. 2021)
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Defendants Williams, Bennett, Johnson, and Farris pleaded guilty to conspiracy to distribute and possess with intent to distribute 500 grams or more of methamphetamine. Although defendants' pleas did not specify that the methamphetamine was of Ice-level purity, the district court at sentencing found that the conspiracy involved Ice and that each was responsible for its distribution. The district court sentenced defendants using the drug-quantity table in USSG 2D1.1(c) .
The Fourth Circuit affirmed defendants' sentences, concluding that the district court did not abuse its discretion in deciding not to reject the Ice Guidelines because of the vastness of this conspiracy and the danger posed by Ice and the appropriateness of treating higher purity methamphetamine more seriously than lower purity methamphetamine. The court concluded that the district court must have latitude to consider whatever reliable evidence is available to make its 80% purity determination. While such evidence may be used, it must be sufficiently reliable and specific that it actually supports the government's position that the drug's purity is 80% or above. The court explained that, given the evidence presented as to each of the defendants, it was not clearly erroneous for the district court to determine that the government met its burden of proving the conspiracy involved Ice. Finally, there was no error in sentencing Johnson under criminal history category II.
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