United States v. McReynolds, No. 21-1521 (6th Cir. 2023)
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McReynolds and 17 co-defendants were charged with conspiracy to distribute and to possess with intent to distribute heroin and cocaine, 21 U.S.C. 841(a)(1); 846. The government, using circumstantial evidence, argued that McReynolds was part of the charged conspiracy, and should be held responsible for the drug quantities attributed to the conspiracy. The jury found McReynolds guilty and attributed “less than 100 grams” of heroin and “less than 500 grams” of cocaine to him. His PSR included the drug amounts attributable to the conspiracy–767.66 grams of heroin, 711.56 grams of cocaine, and 263.51 grams of cocaine base. The court adopted the PSR’s drug quantity determinations, calculated McReynolds’ guidelines range at 151-181 months, and imposed a 151-month sentence.
The Sixth Circuit vacated his sentence and remanded, stating that the district court should adequately explain its reasoning if it attributes any drug amounts to McReynolds beyond the jury’s verdict. On remand, the district court did not change its guideline range determination but imposed a 145-month sentence to account for McReynolds’ post-sentencing positive conduct. The court concluded that the PSR correctly calculated the drug quantity attributable to McReynolds because that quantity was within the scope of his conspiratorial agreement and foreseeable to him but opined that the jury was “confused” and cited three key witness testimonies.
The Sixth Circuit again vacated the sentence. Because the higher drug quantities were not supported by a preponderance of the evidence, McReynolds’ sentence is substantively unreasonable.
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