United States v. Detloff, No. 14-2002 (6th Cir. 2015)
Annotate this CaseDefendant was stopped while driving because his license plate had been reported stolen. Defendant fled on foot, but eventually surrendered. A search of his vehicle uncovered eight falsified driver’s licenses and many pieces of mail addressed to Michigan businesses. A later search of his home revealed 112 stolen business checks and related items. Defendant pled guilty to state charges of resisting an officer. Defendant later pled guilty to mail theft, 18 U.S.C. 1708. The parties agreed to a guidelines range of 57 to 71 months. At the hearing, Defendant entered a plea of guilty to a supervised release violation. Three months later, Defendant filed a pro se motion to withdraw his plea, claiming violations the Interstate Agreement on Detainers, the Speedy Trial Act, and the Sixth Amendment. The court denied his attorney’s motion to withdraw, denied the motion to withdraw the guilty plea, and sentenced Defendant to 60 months on the mail theft charge, to run concurrently with any undischarged state sentence. The court imposed a 24-month sentence, at the bottom of the guidelines range, for a Grade A supervised release violation, to be served consecutively. The Sixth Circuit dismissed an appeal of the mail theft conviction and sentence, but vacated the supervised release sentence. The government conceded that the sentence resulted from a mistaken guidelines calculation.
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