Sentencing Guidelines

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Case Name: Molina-Martinez v. United States

Case No.: 14-8913

Courts reviewing guidelines errors cannot apply a categorical additional evidence rule in cases where a district court applies an incorrect range but sentences the defendant within the correct range.

“The Guidelines establish the essential framework for sentencing proceedings. Sentencing courts “ ‘must begin their analysis with the Guidelines and remain cognizant of them throughout the sentencing process.’ ” Peugh v. United States, 569 U. S. ___, ___. Sentencing Commission statistics confirm that the Guidelines inform and instruct the district court’s determination of an appropriate sentence. In the usual case, the systemic function of the selected Guidelines range will affect a defendant’s sentence. As a result, a defendant who shows that the district court mistakenly deemed applicable an incorrect, higher range will, in the ordinary case, have demonstrated a reasonable probability of a different outcome. That showing will suffice for relief if Rule 52(b)’s other requirements are met”

Reversed and Remanded

Concurring: ALITO, THOMAS

Dissenting:

Attorney Derek A. Hawkins is the managing partner at Hawkins Law Offices LLC, where he heads up the firm’s startup law practice. He specializes in business formation, corporate governance, intellectual property protection, private equity and venture capital funding and mergers & acquisitions. Check out the website at www.hawkins-lawoffices.com or contact them at 262-737-8825.