United States v. Yates, No. 22-2994 (7th Cir. 2024)
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The case involves two defendants, Christopher Yates and Shawn Connelly, who were convicted for conspiring to distribute methamphetamine. The conspiracy operated out of Macomb, Illinois, and lasted thirteen months, from January 2019 to February 2020. Yates supplied the drugs, initially from an unknown source in Joliet, Illinois, with alleged Mexican cartel connections. After the arrest of that supplier, Yates sought a new source. Connelly was among the distributors. The government conducted one seizure and nine controlled buys from members of the conspiracy during its investigation.
In the United States District Court for the Central District of Illinois, both defendants pleaded guilty without a plea agreement. The main dispute at Yates’s sentencing was the classification of the methamphetamine attributable to him as “ice” or “actual” (i.e., pure) methamphetamine, as opposed to its generic variant. The district court found that all 737.1 grams of methamphetamine for which the conspiracy was accountable was “ice” methamphetamine. Connelly raised two objections to the PSR at his sentencing hearing. He argued that the court could not rely on the statements of his coconspirators, Amber Phelps and Jeanna Rechkemmer, for purposes of determining the amount of methamphetamine handled by the conspiracy. He also contended that the full drug weight attributed to the conspiracy was not reasonably foreseeable to him. The district court denied both objections.
In the United States Court of Appeals For the Seventh Circuit, Yates challenged the district court’s finding that the methamphetamine attributable to the conspiracy was “ice” methamphetamine. Connelly once more attacked the district court’s calculation of the total drug weight attributable to him. The court vacated Yates’s sentence and remanded. The court found that the government must supply reliable evidence making that approximation reasonable. Because such evidence was lacking, Yates is entitled to resentencing. The court affirmed Connelly’s sentence.
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