United States v. Antoine Wiggins

CourtCourt of Appeals for the Third Circuit
DecidedSeptember 27, 2024
Docket22-2831
StatusUnpublished

This text of United States v. Antoine Wiggins (United States v. Antoine Wiggins) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Antoine Wiggins, (3d Cir. 2024).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ____________

No. 22-2831 ____________ UNITED STATES OF AMERICA

v.

ANTOINE WIGGINS, Appellant ____________

On Appeal from the United States District Court for the District of New Jersey (D.C. No. 1:18-cr-00459-001) District Judge: Honorable Noel L. Hillman ____________

Submitted Pursuant to Third Circuit L.A.R. 34.1(a) September 17, 2024 ____________ Before: RESTREPO, PHIPPS, and McKEE, Circuit Judges

(Filed: September 27, 2024) ___________

OPINION * ___________

PHIPPS, Circuit Judge.

After Antoine Wiggins pleaded guilty to being a felon in possession of a firearm, see 18 U.S.C. § 922(g)(1), the District Court calculated his sentencing range as 100 to

120 months, as capped by the ten-year statutory maximum, before varying downward and

sentencing Wiggins to 96 months in prison. See id. § 924(a)(2) (2012) (amended by the

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. Bipartisan Safer Communities Act, Pub. L. No. 117-159, 136 Stat. 1313, 1329 (2022) (removing the statutory maximum for 18 U.S.C. § 922(g))). Wiggins now brings two

challenges to the calculation of the Guidelines range for his sentence. On de novo review

of issues of law, see United States v. Caraballo, 88 F.4th 239, 243 (3d Cir. 2023), and review of factual findings for clear error, see id. at 243–44, we will affirm the sentence

imposed.

On May 28, 2018, police stopped Wiggins for driving without a seatbelt in Camden, New Jersey. During the stop, they learned of an active warrant for his arrest, and Wiggins

briefly attempted to flee on foot. The police apprehended him, and he then told them that

he had a handgun in the center console of his car and drugs in its trunk. Wiggins provided consent to search in writing and, consistent with his prior statement, the police uncovered

a .22 caliber Beretta handgun, with a round in the chamber and seven more in the magazine,

as well as crack cocaine in fifty-seven plastic containers of assorted color. After he was

charged with one count of being a felon-in-possession of a firearm in violation of 18 U.S.C.

§ 922(g)(1), Wiggins pleaded guilty through an open plea in which his sentence was

undetermined.

Wiggins’s initial sentencing hearing was held on January 23, 2020, but then

continued for forty-four months until September 26, 2022, when the District Court

sentenced him to 96 months in prison. The District Court arrived at that sentence by using

a base offense level of 24 after finding that Wiggins committed the firearm offense

following “at least two felony convictions of . . . a controlled substance offense.” U.S.S.G

§ 2K2.1(a)(2); see also id. § 4B1.2(b) (defining ‘controlled substance offense’). From

there, the District Court applied a four-level enhancement based on its finding that Wiggins

possessed the firearm in connection with another felony. See id. § 2K2.1(b)(6)(B).

2 Those findings, which took the offense level up to 28, along with a three-level downward adjustment for acceptance of responsibility, which reduced the offense level to

25, see id. § 3E1.1(a)–(b), and a criminal history in Category V, generated a Guidelines

range of 100 to 125 months, which, by statute, could not exceed 120 months, see U.S.S.G. ch. 5, pt. A; see also 18 U.S.C. § 924(a)(2) (2012). Then, after considering Wiggins’s

allocution and the factors enumerated in 18 U.S.C. § 3553(a), the District Court varied

downward to impose a 96-month prison term. Wiggins timely invoked this Court’s appellate jurisdiction to challenge the base

offense level of 24 and the four-level enhancement. See 18 U.S.C. § 3742(a); Fed. R. App.

P. 4(b); see also 18 U.S.C. § 3231 (giving district courts original and exclusive jurisdiction in federal criminal cases). If he succeeds on both fronts, his total offense level would be

12 and his new Guidelines range would be 27 to 33 months in prison. See U.S.S.G.

§§ 2K2.1(a)(6)(A) (providing a base offense level of 14 if the defendant is prohibited from

possessing a firearm at the time of the offense), 3E1.1(b) (limiting the reduction for

acceptance of responsibility to two levels if the total offense level is below 16 before the

application of any responsibility decrease). 1

I. Wiggins’s challenge to the base offense level fails under Circuit precedent. In

United States v. Lewis, 58 F.4th 764 (3d Cir. 2023), this Court determined that the term ‘controlled substance’ in the Guidelines refers to a “drug regulated by either state or federal

1 If only his base-level challenge were successful, then that level of 14 would be increased by a net of one (plus four from the § 2K2.1(b)(6)(B) enhancement and minus three for acceptance of responsibility) yielding a sentencing range of 37 to 46 months. See U.S.S.G. § 2K2.1(a)(6)(A); see also id. § 3E1.1(b). If only the challenge to the four-level enhancement were successful, then his offense level of 25 would be reduced by four to 21 and the sentencing range would be 70 to 87 months. See id. § 2K2.1(a)(6)(A); id. § 3E1.1(b); see also id. § 2K2.1(b)(6)(B); see generally U.S.S.G. ch. 5, pt. A.

3 law.” Id. at 771. Still, Wiggins argues that only convictions for violations of state laws that categorically match the drugs regulated under the Controlled Substances Act, see

21 U.S.C. § 812 (providing schedules of controlled substances), may constitute “controlled

substance offense[s]” under the Guidelines, so the District Court should have concluded that his base offense level was 14, see U.S.S.G. § 2K2.1(a)(6)(A), rather than 24, see id.

§ 2K2.1(a)(2). But that argument is foreclosed by Lewis, as Wiggins concedes. Thus, the

District Court correctly concluded that it did not need to determine whether New Jersey law defines ‘cocaine’ more broadly than federal law before it found that Wiggins’s prior

convictions for cocaine distribution were “controlled substance offense[s].” U.S.S.G.

§ 2K2.1(a)(2); see also Lewis, 58 F.4th at 771.

II. The District Court likewise did not err in applying the four-level enhancement under

Guideline § 2K2.1(b)(6)(B). That subsection of the Guidelines imposes a four-level

enhancement when a firearm is used or possessed “in connection with another felony.”

U.S.S.G. § 2K2.1(b)(6)(B). Based on these principles, Wiggins raises three challenges:

(i) that he was not engaged in another felony because he was not drug trafficking; (ii) that

even if he was drug trafficking, his possession of the Beretta .22 was not in connection

with that activity; and (iii) that he rebutted any presumption that his firearm was connected

with the drug trafficking.

A. Ample record evidence supports the District Court’s conclusion that Wiggins was

drug trafficking.

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Related

United States v. West
643 F.3d 102 (Third Circuit, 2011)
United States v. Raymond Napolitan
762 F.3d 297 (Third Circuit, 2014)

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