United States v. Jones, No. 22-1281 (6th Cir. 2023)
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Jones, who was on supervised release, was arrested after he fired shots outside his house and fled inside. He pled guilty to possessing a stolen firearm. The district court imposed the agreed-upon 10-year sentence, which was above the 77-96 month Guidelines range but below the 15-year mandatory minimum that would have applied if he had been classified as an armed career criminal. The court rejected arguments that he should not receive a sentence enhancement for reckless endangerment during flight and challenging the use of his prior controlled substance offense under Michigan state law to increase his base offense level–claiming Michigan’s controlled-substance statute is broader than the federal definition of the relevant substances. Separately, Jones faced resentencing on his supervised release; the firearm offense violated his supervised release conditions. A different district court imposed a 24-month sentence—half to run concurrently with his firearm conviction and half to run consecutively.
The Third Circuit affirmed. The district courts properly calculated Jones’s Guidelines range for the firearm offense and imposed a reasonable sentence for the supervised-release violation.
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