United States v. Valentine, No. 11-1296 (6th Cir. 2012)
Annotate this CaseDefendants, involved in a large-scale drug operation, 1991-1999, were convicted of conspiracy to distribute and possess with the intent to distribute cocaine base, 21 U.S.C. 841(a)(1) and 846. Presentence Investigation Reports concluded that criminal activity for each defendant involved more than 1.5 kilograms of crack cocaine, and recommended that each receive the highest base-offense level of 38. The court noted concerns about the total quantities involved, but overruled defendants’ objections and sentenced each to the lowest sentence within the range. The Sixth Circuit affirmed the convictions and sentences on direct appeal. Defendants later moved for sentence modifications under 18 U.S.C. 3582(c)(2) based on Sentencing Guidelines Amendments 706 and 711, which were made retroactive. A district judge found that three defendants were not eligible for modifications because a preponderance of the evidence established that they were responsible for more than 4.5 kilograms of crack. With respect to another, a different judge reduced the sentence by six months, reasoning that finding that he was responsible for more than 4.5 kilograms of crack would be functionally inconsistent with the original finding that he was responsible for “at least 1.5 kilograms.” The Sixth Circuit affirmed the denials of modifications and reversed the sentence reduction.
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