Abuse of Discretion Sentencing Guidelines.

Byline: Derek Hawkins

7th Circuit Court of Appeals

Case Name: United States of America v. Joel J. Helding

Case No.: 18-3270

Officials: HAMILTON, SCUDDER, and ST. EVE, Circuit Judges.

Focus: Abuse of Discretion Sentencing Guidelines

Police seized 143.7 kilograms of marijuana from Joel Helding's car and apartment, and he pleaded guilty to possessing over 100 kilograms. But at sentencing, the district court held him responsible for the equivalent of 4,679.7 kilogramsover 32 times the amount seized. The additional quantity was based solely on the Presentence Investigation Report's account that confidential informants told law enforcement Helding was dealing significant quantities of methamphetamine during the relevant period. The drug quantity determination had a sizeable effect on Helding's advisory guidelines range, and it drove his ultimate sentence of 18 years' imprisonment.

A sentencing court acts within its discretion when it credits confidential informants' statements about drug quantity, but when a defendant objects, the...