United States v. Histed, No. 22-2080 (6th Cir. 2024)
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Zachariah Histed pleaded guilty to possessing methamphetamine with intent to distribute. The District Court for the Western District of Michigan sentenced him to 300 months' imprisonment. Histed appealed his sentence on both procedural and substantive grounds, arguing that the district court incorrectly calculated the drug quantity, wrongly applied multiple sentencing enhancements, improperly denied him credit for acceptance of responsibility, and imposed a sentence that was too long.
The United States Court of Appeals for the Sixth Circuit affirmed in part, vacated Histed’s sentence, and remanded for resentencing. The Court of Appeals held that the district court erred in calculating the quantity of methamphetamine attributable to Histed because it did not adequately explain how it arrived at the drug quantity or articulate any methodology for reaching the offense level of 32. Thus, the Court of Appeals vacated Histed's sentence and remanded the case for resentencing with a more precise determination of the drug quantity attributable to Histed.
However, the Court of Appeals affirmed the district court's application of the dangerous-weapon, reckless-endangerment, and obstruction-of-justice enhancements, as well as its denial of an acceptance-of-responsibility reduction. The court found that Histed's possession of an inert grenade during his drug-trafficking offense justified the dangerous-weapon enhancement. It also held that Histed's reckless behavior during his flight from law enforcement warranted the reckless-endangerment enhancement, and his attempts to make others lie to investigators justified the obstruction-of-justice enhancement. Finally, the court held that despite Histed's guilty plea, his lack of full acceptance of responsibility for his actions justified the denial of an acceptance-of-responsibility reduction.
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