Sentencing-Premises Enhancement

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7^th Circuit Court of Appeals

Case Name: United States of America v. Randy Craft

Case No.: 22-3015

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

Focus: Sentencing-Premises Enhancement

In October 2019, Randall Craft admitted guilt to a charge of conspiring to distribute more than fifty grams of methamphetamine. His sentence was set at 150 months behind bars, along with five years of supervised release. The district court added two enhancements to the sentence: one for the alleged use of premises for drug-related activities and another for Craft’s managerial role in the operation.

The Seventh Circuit disagreed with the district court’s decision on the premises enhancement, stating that there wasn’t enough evidence to prove that Craft primarily used his residence for drug-related activities. However, they upheld the two-level enhancement for Craft’s significant role in the conspiracy.

Consequently, the appeals court overturned Craft’s sentence and sent the case back to the district court for resentencing, instructing them to consider the appellate court’s findings regarding the sentencing enhancements.

Vacated and remanded.

Decided 04/22/24

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