United States v. Chatman, No. 14-2519 (7th Cir. 2015)
Annotate this CaseChatman was charged with six counts of distributing heroin, 21 U.S.C. 841(a)(1), based on separate transactions between Chatman and an undercover agent. He pled guilty to one count, his sixteenth criminal conviction since 1996 and third for delivery of a controlled substance. He had convictions for possession of a controlled substance, unlawful use of a weapon by a felon, domestic battery, driving under the influence, and driving on a suspended or revoked license. At Chatman’s sentencing hearing, when describing Chatman’s criminal history, the government stated that Chatman had “several” possession of a controlled substance convictions and “several” DUI convictions. After hearing arguments, the court assigned him 27 criminal history points under U.S.S.G. 4A1.1, which produced a Category VI criminal history designation. The court matched this criminal history designation with the instant offense score of 29 to reach a suggested sentence of 151 to 188 months. The court heard arguments regarding the 18 U.S.C. 3553(a) factors, then sentenced Chatman to 160 months in prison and three years of supervised release, with conditions including refraining from “excessive use of alcohol,” and of “any narcotics,” and having a mental health evaluation during supervised release. The Seventh Circuit affirmed, rejecting an argument that the court improperly relied on inaccurate statements by the government regarding his criminal history, but modified to expunging a mental health evaluation that was not orally pronounced from the bench.
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