United States v. Christopher Coffer

CourtCourt of Appeals for the Sixth Circuit
DecidedJuly 15, 2021
Docket20-3898
StatusUnpublished

This text of United States v. Christopher Coffer (United States v. Christopher Coffer) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth 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. Christopher Coffer, (6th Cir. 2021).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 21a0341n.06

No. 20-3898

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Jul 15, 2021 ) UNITED STATES OF AMERICA, DEBORAH S. HUNT, Clerk ) ) Plaintiff-Appellee, ) ON APPEAL FROM THE UNITED ) STATES DISTRICT COURT FOR v. ) THE NORTHERN DISTRICT OF ) OHIO CHRISTOPHER COFFER, ) ) Defendant-Appellant. )

BEFORE: BATCHELDER, WHITE, and DONALD, Circuit Judges.

PER CURIAM. Christopher Coffer appeals his 121-month sentence for child pornography

offenses. As set forth below, we AFFIRM.

Admitting that he used file-sharing software to download and trade child pornography,

Coffer pleaded guilty to receipt and distribution of visual depictions of minors engaged in sexually

explicit conduct, in violation of 18 U.S.C. § 2252(a)(2), and possession of child pornography, in

violation of 18 U.S.C. § 2252A(a)(5)(B). Coffer’s presentence report set forth a guidelines range

of 151-to-188 months of imprisonment based on a total offense level of 34 and a criminal-history

category of I. Coffer requested a downward variance from that range based on his health issues,

asserting that he receives disability benefits for diabetic nephropathy and suffers from various

other ailments and that his health conditions place him at higher risk of death or complications

from COVID-19. At sentencing, the district court denied Coffer’s request for a downward

variance based on his health issues, noting that the Bureau of Prisons (BOP) “manages many No. 20-3898, United States v. Coffer

serious health concerns,” but nevertheless varied downward based on the sentencing factors under

18 U.S.C. § 3553(a). (R. 51, PageID 300). The district court sentenced Coffer to 121 months of

imprisonment, a sentence below his Guidelines range, and delayed his report date to allow him to

undergo and recover from his scheduled medical procedures.

In this timely appeal, Coffer challenges his 121-month sentence. We review a defendant’s

sentence for procedural and substantive reasonableness under an abuse-of-discretion standard.

Gall v. United States, 552 U.S. 38, 51 (2007); United States v. Libbey-Tipton, 948 F.3d 694, 705

(6th Cir. 2020). Coffer cites the standard of review for a procedural issue—whether the district

court adequately explained its sentencing decision—but makes a substantive argument—whether

the district court placed enough weight on his health issues.

To the extent that Coffer raises a procedural challenge to his sentence, the government

argues that plain-error review applies because, when given the opportunity to object to the district

court’s sentencing determination, defense counsel did not object on the basis that the district court

did not adequately explain its refusal to vary downward based on Coffer’s health issues. See

United States v. Vonner, 516 F.3d 382, 386 (6th Cir. 2008) (en banc). Regardless of the standard

of review, the district court adequately explained its decision to deny Coffer’s request for a

downward variance based on his health issues. A sentencing explanation satisfies the requirements

of procedural reasonableness if the sentencing judge “set[s] forth enough to satisfy the appellate

court that [s]he has considered the parties’ arguments and has a reasoned basis for exercising [her]

own legal decisionmaking authority.” Rita v. United States, 551 U.S. 338, 356 (2007). The district

court specifically addressed Coffer’s health conditions, concluding that those conditions, even in

the context of the COVID-19 pandemic, did not justify a downward variance:

Get new teeth. BOP can manage that all day long. The BOP manages many serious health concerns. Diabetes is one of them. It can be managed. And it is one that is

-2- No. 20-3898, United States v. Coffer

likely to lead to a higher risk for COVID. But you can be kept safe in a prison environment, also with hypertension.

....

I don’t find, sir, that your health condition or the likely result of any single condition, diabetes, hypertension or the others, justify a variance downwards or departure. The Bureau of Prisons cares for many persons who are ill.

COVID is a reality, and it’s certainly something that I keep in mind when I sentence to incarceration, because it is a different environment, one that doesn’t necessarily allow you the personal privileges you enjoy at home, but it doesn’t necessarily mean that you’re more likely to contract COVID, but it does mean that extra care will be taken.

So there is no justification for a variance downwards due to your health or the implications of COVID on that health.

(R. 51, PageID 300-01). The district court provided an adequate explanation to satisfy the

requirements of procedural reasonableness.

Coffer frames the issue for review as follows: “What is the extent of medical disadvantage

that a defendant must present in order to secure a variance based on ill health?” (Appellant’s Br.

6). Coffer essentially raises a substantive challenge to his sentence—that the district court gave

insufficient weight to his health issues. See United States v. Rayyan, 885 F.3d 436, 442 (6th Cir.

2018) (holding that a claim that a sentence is substantively unreasonable is “a complaint that the

court placed too much weight on some of the § 3553(a) factors and too little on others”). A

sentence’s substantive reasonableness is “a matter of reasoned discretion, not math, and our highly

deferential review of a district court’s sentencing decisions reflects as much.” Id. Given that we

afford a within-guidelines sentence a rebuttable presumption of substantive reasonableness,

Coffer’s burden of demonstrating that his below-guidelines sentence is “unreasonably long is even

more demanding.” United States v. Curry, 536 F.3d 571, 573 (6th Cir. 2008); see also United

States v. Greco, 734 F.3d 441, 450 (6th Cir. 2013) (“Although it is not impossible to succeed on a

-3- No. 20-3898, United States v. Coffer

substantive-reasonableness challenge to a below-guidelines sentence, defendants who seek to do

so bear a heavy burden.”).

Coffer has not satisfied that demanding burden. The district court denied Coffer’s request

for a downward variance based on his health issues, pointing out that the BOP “manages many

serious health concerns.” (R. 51, PageID 300). The district court determined that Coffer’s

arguments about his health issues and the COVID-19 pandemic were arguments that supported the

delay of his report date, which the district court allowed. The district court observed that Coffer

had failed to acknowledge his intentional harm to real victims and that “no one . . . should have

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

Related

Rita v. United States
551 U.S. 338 (Supreme Court, 2007)
Gall v. United States
552 U.S. 38 (Supreme Court, 2007)
United States v. Almenas
553 F.3d 27 (First Circuit, 2009)
United States v. Theunick
651 F.3d 578 (Sixth Circuit, 2011)
United States v. Thomas Greco, Jr.
734 F.3d 441 (Sixth Circuit, 2013)
United States v. Myers
503 F.3d 676 (Eighth Circuit, 2007)
United States v. Vonner
516 F.3d 382 (Sixth Circuit, 2008)
United States v. Curry
536 F.3d 571 (Sixth Circuit, 2008)
United States v. Khalil Abu Rayyan
885 F.3d 436 (Sixth Circuit, 2018)
United States v. Adam Libbey-Tipton
948 F.3d 694 (Sixth Circuit, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Christopher Coffer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-christopher-coffer-ca6-2021.