United States v. Washington, No. 19-1938 (8th Cir. 2020)
Annotate this CaseAfter defendant pleaded guilty to one count of conspiring to distribute cocaine base and heroin, he was sentenced to a below-Guidelines sentence of 160 months' imprisonment. The Eighth Circuit held that the district court's competency determination was supported by more than ample evidence, was not clearly erroneous, and was not sufficiently close to consider the burden of proof as a potential source of error. The court also held that there was no error in the district court's drug quantity or firearm-related Guidelines determinations. Finally, the court held that defendant's sentence was substantively reasonable and the district court did not abuse its discretion in weighing defendant's role in the conspiracy and his physical and mental limitations.
Court Description: [Melloy, Author, with Smith, Chief Judge, and Shepherd, Circuit Judge] Criminal case - Criminal law and sentencing. The district court did not err in finding defendant was competent to stand trial; the district court did not err in determining the amount of drugs for which defendant was responsible or in imposing a firearms enhancement pursuant to Guidelines Sec. 2D1.1(b)(1); defendant's below-guidelines sentence was substantive reasonable.
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