James Bayless v. United States

14 F.3d 410, 1994 WL 12538
CourtCourt of Appeals for the Eighth Circuit
DecidedMarch 22, 1994
Docket93-1039
StatusPublished
Cited by8 cases

This text of 14 F.3d 410 (James Bayless v. United States) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Bayless v. United States, 14 F.3d 410, 1994 WL 12538 (8th Cir. 1994).

Opinions

FAGG, Circuit Judge.

After partially granting James Bayless’s 28 U.S.C. § 2255 motion to correct his pre-Guidelines sentence, the district court resen-tenced Bayless. Bayless appeals and we affirm.

Bayless and five others were charged with conspiring to distribute cocaine and marijuana from 1983 through 1986. Four of Bay-less’s coconspirators were quickly tried and convicted while Bayless remained at large. [411]*411Three of the coconspirators were sentenced to parolable terms of imprisonment under the version of 21 U.S.C. § 841(b)(1)(B) in effect before October 27, 1986. The cocon-spirators appealed, and we reversed and remanded for resentencing because the cocon-spirators’ drug activities straddled the effective date of § 841’s amendment, which does not permit parole. United States v. McConnell, 903 F.2d 566, 572-73 (8th Cir.1990), cert. denied, 498 U.S. 1106, 111 S.Ct. 1011, 112 L.Ed.2d 1093, and cert. denied, 499 U.S. 938, 111 S.Ct. 1393, 113 L.Ed.2d 449 (1991).

Bayless was later apprehended and convicted of conspiracy to distribute cocaine and marijuana. Referring to our earlier decision in McConnell, the district court sentenced Bayless to a nonparolable ten-year term of imprisonment under the amended version of § 841(b)(1)(B). We affirmed Bayless’s conviction and sentence on direct appeal. United States v. Bayless, 940 F.2d 300 (8th Cir.1991). Bayless then filed a motion under 28 U.S.C. § 2255 asserting he should have been sentenced to a parolable term under the earlier version of 21 U.S.C. § 841(b)(1)(B), because the statute’s amendment became effective after he affirmatively withdrew from the conspiracy. Bayless thus asserted his sentence under the amended statute violated the Ex Post Facto Clause. The Government agreed that Bayless should not have been sentenced under the amended statute. Although Bayless had not raised the issue in his direct appeal, the district court found it could consider the issue’s merits because Bayless was sentenced under the wrong statute. See Jones v. Arkansas, 929 F.2d 375, 381 (8th Cir.1991) (applying procedural default’s actual innocence exception to defendant sentenced under an inapplicable statute). The district court found Bayless’s participation in the conspiracy ended in September 1986, before § 841(b)(1)(B) was amended. Because the sentencing court had erroneously believed it could not sentence Bayless to a parolable term, the district court granted Bayless’s § 2255 motion in part.

At Bayless’s resentencing, the original sentencing judge did not preside. A different judge was provided with a supplemental pre-sentence report (PSR). Like the original PSR, the supplemental PSR stated the overall scope of the conspiracy involved distribution of 130 kilograms of cocaine and between 31,200 and 35,100 pounds of marijuana. The PSR did not attribute any specific quantities to Bayless. Instead, the PSR referred to testimony at the eoconspirators’ trial estimating that in 1984 and 1985 an informant bought cocaine from Bayless “approximately 100 times in quantities ranging from grams to ounces.” Bayless objected to the PSR’s drug quantity estimate asserting he should not be held accountable for the entire amount, which encompassed the coconspira-tors’ activities after his withdrawal, and to the PSR’s characterization of his role in the offense. Bayless acknowledged he could be held accountable for ten to twelve pounds (about 4.5 to about 5.5 kilograms) of cocaine, and this amount supported a ten-year sentence. Nevertheless, Bayless asked the court to make a specific quantity finding because the quantity would affect the amount of time Bayless would have to serve in prison before being paroled. The district court stated that the disputed drug amount would not affect Bayless’s sentence, and the court would not consider Bayless’s role in the offense when imposing the sentence. The district court resentenced Bayless to the same ten-year term of imprisonment, but stated Bayless would be eligible for release on parole after serving one-third of his sentence. See 18 U.S.C. § 4205(a), (b) (repealed effective Nov. 1, 1992).

On appeal, Bayless contends the district court’s failure to make specific findings about drug quantity and his role in the offense, and its failure to attach written findings to the PSR, violates Federal Rule of Criminal Procedure 32(c)(3)(D).

When a defendant challenges the factual accuracy of information contained in the PSR, Federal Rule of Criminal Procedure 32(e)(3)(D) gives a dis0trict court two options. The district court must either make specific findings resolving the disputed matters, or decide no findings are necessary because the contested information will not be considered at sentencing. Fed.R.Crim.P. 32(c)(3)(D); United States v. Candie, 974 F.2d 61, 64 (8th Cir.1992). To provide a clear record of the [412]*412disposition of the PSR’s disputed facts for appellate courts and agencies like the Parole Commission, Rule 32 also requires a district court to attach a written record of the court’s specific findings resolving the disputes, or a written decision identifying the disputed matters and concluding that findings are unnecessary, to any copy of the PSR provided to the Bureau of Prisons. Fed.R.Crim.P. 32(c)(3)(D); id. advisory committee’s note to 1983 amendment; Candie, 974 F.2d at 64; see United States v. Coonce, 961 F.2d 1268, 1277 (7th Cir.1992) (purpose of attachment requirement).

Here, the district court complied with Rule 32(c)(3)(D) by deciding no findings were necessary because the disputed drug quantity and Bayless’s role in the offense would not be considered at sentencing. Indeed, Bay-less concedes the disputed matter does not affect his sentence, but contends the district court should have made findings anyway because the contested information affects his offense severity rating on the parole guideline worksheet. See 28 C.F.R. § 2.20 (1993); United States v. Boatner, 966 F.2d 1575, 1579 (11th Cir.1992) (explaining Parole Commission’s decision making in pre-Guidelines cases).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
14 F.3d 410, 1994 WL 12538, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-bayless-v-united-states-ca8-1994.