United States v. Browne, No. 22-3333 (8th Cir. 2023)
Annotate this CaseThe United States Court of Appeals for the Eighth Circuit affirmed the sentences of Theodore Browne and Karley Ann Smith, both of whom had pled guilty to conspiring to distribute 50 grams or more of methamphetamine. Browne claimed that the district court erred in determining that he transported 10 pounds of meth, which influenced his base offense level. However, the Appeals Court ruled that the district court's approximation of the drug quantity, based on witness testimonies, was not clearly erroneous. Browne also argued that the district court wrongly applied a 4-level role enhancement, contending that there was insufficient evidence to show he was an "organizer or leader" of the conspiracy. The Appeals Court disagreed, ruling that the district court's finding was not clearly erroneous based on witness testimonies. Smith argued that the district court abused its discretion by considering late-filed evidence in the government’s sentencing memorandum, which resulted in the imposition of an obstruction enhancement and the denial of an acceptance-of-responsibility reduction. The Appeals Court ruled that Smith had sufficient time to review and respond to the challenged exhibits, and that the district court did not err in finding obstruction of justice and rejecting the acceptance-of-responsibility reduction.
Court Description: [Benton, Author, with Colloton and Wollman, Circuit Judges] Criminal case - Sentencing. The district court did not err in calculating the amount of drugs attributable to defendant Browne based on the evidence presented at sentencing; the district court did not err in imposing a four-level role enhancement under Guidelines 3B1.1(a) as defendant Browne played a leadership or organizer role in the offense; the district court did not abuse its discretion in admitting certain evidence concerning obstruction of justice in considering defendant Smith's sentence, and the court did not err in imposing the obstruction enhancement or in rejecting Smith's request for acceptance-of-responsibility.
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