United States v. Hamilton, No. 17-3794 (8th Cir. 2019)
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The Eighth Circuit affirmed defendant's conviction for conspiracy to distribute one kilogram or more of PCP and life term of imprisonment. The court held that the evidence was sufficient to show that defendant knew the parcels he sent from California to Kansas City contained cans of PCP, and the evidence also corroborated the testimony of the cooperating witnesses.
The court also held that, even if the district court erred by imposing a two-level sentencing enhancement under USSG 3C1.1 for obstruction of justice, the error was harmless. In this case, the sentencing judge based the sentence on factors independent of the Sentencing Guidelines and thus any miscalculation of defendant's Guidelines sentence was harmless.
Court Description: Grasz, Author, with Gruender and Kelly, Circuit Judges] Criminal case - Criminal law and sentencing. Evidence was sufficient to support defendant's conviction for conspiring to distribute PCP; even if the district court erred in imposing a two-level enhancement under Guidelines Sec. 3C1.1 based on its findings that defendant threatened cooperating witnesses, the error was harmless as it only increased defendant's offense level from 44 to 46 points, both of which totals are above the 43-level cap on offense level; further, the court stated it would impose the same sentence regardless of its calculation of the guidelines.
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