Postconviction Motion – Sentence Reduction

7^th Circuit Court of Appeals

Case Name: United States of America v. Joseph Miedzianowski

Case No.: 21-2358

Officials: Hamilton, Kirsch, and Jackson-Akiwumi, Circuit Judges.

Focus: Postconviction Motion – Sentence Reduction

Appellant Miedzianowski is serving a life sentence for leading a criminal conspiracy while he was also working as a Chicago police officer. Two decades after his conviction, he moved the district court for a sentence reduction under Section 404(b) of the First Step Act. He asserted that a reduction was justified by his post-sentencing conduct, his advanced age, and what he says are unwarranted disparities between his sentence and the sentences of similarly situated defendants. The district court found that defendant is legally eligible for relief but exercised its discretion to deny a reduction based on the seriousness of his crimes. On appeal, defendant argues that the court erred by failing to address several of his arguments and by not giving enough weight to his arguments in mitigation. Defendant’s sentence was within the guideline range, and the Guidelines inherently address disparities among defendants. The court explained that defendant’s actions warranted a longer sentence because he had “higher culpability” as the leader of the conspiracy. The court sufficiently addressed defendant’s arguments and did not abuse its discretion by denying his motion.

Affirmed.

Decided 02/24/23

Full Text