Resentencing

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7^th Circuit Court of Appeals

Case Name: United States of America v. Christopher Yates

Case No.: 22-2994

Officials: Wood, Scudder, and St. Eve, Circuit Judges.

Focus: Resentencing

Christopher Yates and Shawn Connelly were found guilty of conspiring to distribute methamphetamine in Macomb, Illinois, spanning thirteen months from January 2019 to February 2020. Initially, Yates sourced the drugs from an unidentified supplier in Joliet, Illinois, purportedly linked to a Mexican cartel. Following the supplier’s arrest, Yates sought a new source, while Connelly was involved in distribution. Government investigations included one seizure and nine controlled buys from conspiracy members.

In the Central District of Illinois, both defendants pleaded guilty without a plea agreement. During Yates’s sentencing, a key point of contention was whether the methamphetamine attributable to him should be classified as “ice” or “actual” (i.e., pure) methamphetamine, as opposed to the generic variant. The court determined that all 737.1 grams of methamphetamine associated with the conspiracy were of the “ice” variety. At Connelly’s sentencing, he raised objections to the Pre-Sentence Report (PSR), arguing against relying on co-conspirators’ statements for determining drug amounts and disputing the foreseeability of the total drug weight attributed to him. The district court dismissed both objections.

Yates contested the district court’s classification of the methamphetamine as “ice,” while Connelly challenged the calculation of drug weight attributed to him. The Seventh Circuit vacated Yates’s sentence, ruling that the government must provide reliable evidence to support such determinations. As such evidence was lacking, Yates was granted resentencing. Connelly’s sentence was affirmed by the court.

Vacated and remanded in part. Affirmed in part

Decided 04/11/24

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