United States v. Brown, No. 14-1252 (8th Cir. 2014)
Annotate this CaseBrown pled guilty to distributing about six grams of crack cocaine, 21 U.S.C. 841(a)(1) and 841(b)(1)(C). The district court calculated a guideline range of 151 to 188 months based on Brown's offense level of 29 and criminal history category VI. The government requested a sentence of 151 months based on Brown's prior criminal convictions for selling crack cocaine. Brown argued for a downward departure based on his mental health needs and troubled childhood. He claimed that his status as a career offender was overstated because his untreated "schizoaffective disorder" caused his criminal conduct. The district court varied downward, sentencing Brown to 120 months. The Eighth Circuit affirmed, rejecting Brown’s arguments that the district court failed to consider his mental health issues sufficiently and explain his sentence adequately and that his sentence was substantively unreasonable.
Court Description: Criminal case - Sentencing. The district court extensively reviewed defendant's mental health issues and need for treatment and did not erroneously give them only a cursory review; the court adequately explained its sentencing decision and did not impose a substantively unreasonable sentence.
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