United States v. Carter, No. 22-2009 (6th Cir. 2023)
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Kejuan Pharrell Carter was convicted of distributing methamphetamine and sentenced to 108 months' imprisonment by the United States District Court for the Western District of Michigan. On appeal to the United States Court of Appeals for the Sixth Circuit, Carter contended that the district court failed to consider his policy argument for a downward variance from the advisory Sentencing Guidelines range. This argument was grounded in the notion that the Guidelines' focus on drug quantity and purity disproportionately punished low-level offenders due to an increase in the average purity of methamphetamine in circulation since the implementation of the Guidelines.
However, during the sentencing hearing, Carter only briefly referred to his policy argument and primarily focused on his life experiences and characteristics. Upon sentencing, the district court asked if all non-frivolous arguments had been addressed, and both Carter and the government, through their respective counsels, affirmed they had. Carter's appeal claimed that the district court had failed to address his policy argument, but the appeals court held that Carter had either waived this right or invited the error by agreeing that all his arguments had been addressed.
The appeals court affirmed the lower court's decision, ruling that there was no "manifest injustice" that warranted a review of the claimed error, as Carter did not allege a violation of his constitutional rights, and the alleged error did not stem from an obvious mistake such as a Guidelines miscalculation. The court further noted that the strategic decisions of the parties during sentencing, including which arguments to emphasize, reasonably influence the court's response. Thus, Carter's decision to focus primarily on his life experiences and characteristics at the sentencing hearing contributed to the district court's emphasis on these aspects.
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