United States v. Sparks, No. 18-50225 (5th Cir. 2019)Annotate this Case
Defendant appealed his below-Guidelines 35 year sentence for his role in a carjacking with fellow gang members when he was 16 years old. The carjacking resulted in two murders.
The Fifth Circuit held that defendant's sentence did not violate Miller v. Alabama, which prohibits sentencing a juvenile to mandatory life without parole, because defendant received a discretionary sentence under 18 U.S.C. 3553(a) rather than a mandatory sentence; he was sentenced to 35 years in prison rather than life without parole; and he failed to demonstrate a violation of Miller's substantive requirements. Furthermore, defendant was afforded far more than the minimum procedure necessary to conduct a proper section 3553(a) analysis, and Miller did not add procedural requirements over and above section 3553(a). The court also held that the district court did not abuse its discretion by applying two points to defendant's offense level for obstructing justice under USSG 3C1.1, and denying him a two point reduction for accepting responsibility under USSG 3E1.1.