United States v. Cornell James Harp

CourtCourt of Appeals for the Sixth Circuit
DecidedMarch 18, 2025
Docket24-3134
StatusUnpublished

This text of United States v. Cornell James Harp (United States v. Cornell James Harp) 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. Cornell James Harp, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0149n.06

Case No. 24-3134

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Mar 18, 2025 UNITED STATES OF AMERICA, ) KELLY L. STEPHENS, Clerk ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR ) THE NORTHERN DISTRICT OF CORNELL JAMES HARP, ) OHIO Defendant-Appellant. ) OPINION )

Before: SUTTON, Chief Judge; GRIFFIN and MATHIS, Circuit Judges.

MATHIS, Circuit Judge. Cornell Harp pleaded guilty to a felony drug offense and the

district court sentenced him to a 188 months’ imprisonment followed by a lifetime term of

supervised release. Harp challenges his above-Guidelines sentence as procedurally and

substantively unreasonable. Discerning no error, we affirm.

I.

On February 1, 2023, a deputy sheriff with the Portage County Sheriff’s Office pulled Harp

over for traffic violations. During the traffic stop, a trained police dog alerted to the presence of

drugs in Harp’s vehicle. A search revealed numerous bags containing 40,511 methamphetamine

pills, weighing over 10.5 kilograms.

A grand jury indicted Harp for possessing methamphetamine with intent to distribute. Harp

pleaded guilty to the charge pursuant to a written plea agreement. No. 24-3134, United States v. Harp

The case proceeded to sentencing. At the sentencing hearing, the district court determined

that Harp’s advisory Sentencing Guidelines range was 121 to 151 months. This range

corresponded to a total offense level of 31 and a criminal history category of II. Harp’s criminal

history included a federal drug conviction for conspiracy to possess with intent to distribute

cocaine. Harp left prison in 2019 for that conviction to begin serving his term of supervised

release, which terminated in March 2022. The instant offense occurred less than a year after the

termination of his supervised release. Harp’s criminal history computation excluded three felony

convictions and sixteen misdemeanor convictions. The convictions dated back to 1992 when Harp

was eighteen years old and continued until his prior federal drug conviction in 2009.

During the sentencing hearing, the district court advised the parties that it was

contemplating an upward variance based on the nature and circumstances of the offense; Harp’s

criminal history; and the need for the sentence to reflect the seriousness of the offense, provide

just punishment, afford adequate deterrence, and protect the public. After hearing arguments from

the parties, the district court imposed a sentence of 188 months’ imprisonment (37 months above

the high end of the advisory Guidelines range) followed by a lifetime term of supervised release.

After the district court invited objections to the sentence, Harp objected to the upward variance.

The district court noted the objection for the record. This appeal followed.

II.

Harp challenges the reasonableness of his sentence. We review sentences for both

procedural and substantive unreasonableness. Gall v. United States, 552 U.S. 38, 51 (2007).

A.

We review the procedural reasonableness of Harp’s sentence for plain error. This is

because Harp made no argument about the procedural aspects of the sentence to the district court

-2- No. 24-3134, United States v. Harp

and raised no specific objection after being invited to do so. See United States v. Vonner, 516 F.3d

382, 385 (6th Cir. 2008) (en banc); United States v. Bostic, 371 F.3d 865, 872–73 (6th Cir. 2004).

When asked the Bostic question at sentencing, Harp’s counsel replied, “we would object to the

sentence at this time, the upward variance.” R. 51, PageID 271. Harp contends that his Bostic

objection preserved “all of the procedural and substantive arguments regarding the reasonableness

of the District Court’s sentence for this . . . Court’s review.” D. 34 at p.10. We disagree. When

“a party answers the Bostic question in the affirmative, but at such a high degree of generality that

the district court has no opportunity to correct its purported error and the court of appeals has been

deprived of a more detailed record to review,” plain-error review applies. United States v.

Simmons, 587 F.3d 348, 358 (6th Cir. 2009). Harp’s generalized Bostic objection merely reiterated

the argument he made at the sentencing hearing regarding the length of the sentence.

In assessing procedural reasonableness, we must “ensure that the district court committed

no significant procedural error, such as failing to calculate (or improperly calculating) the

Guidelines range, treating the Guidelines as mandatory, failing to consider the § 3553(a) factors,

selecting a sentence based on clearly erroneous facts, or failing to adequately explain the chosen

sentence.” Gall v. United States, 552 U.S. at 51. Under plain-error review, Harp must show

“(1) error, (2) that was obvious or clear, (3) that affected his substantial rights, and (4) affected the

fairness, integrity, or public reputation of his judicial proceedings.” United States v. Gunter, 620

F.3d 642, 645 (6th Cir. 2010). He cannot meet this standard.

Term of Imprisonment. Harp argues the district court erred by failing to notify him that it

was considering an upward variance prior to his sentencing hearing, in violation of Federal Rule

of Criminal Procedure 32(h). Such notice was not required here. Rule 32(h) requires that a district

court provide “reasonable notice that it is contemplating . . . a departure” from the Guidelines. A

-3- No. 24-3134, United States v. Harp

“departure” is a “term of art” that refers to a sentence outside the Guidelines range based on the

district court’s application of a particular Guidelines provision. Irizarry v. United States, 553 U.S.

708, 714 (2008). On the other hand, a “variance” results from the district court’s imposition of a

sentence outside the advisory range as the result of its weighing of the § 3553(a) factors. United

States v. Grams, 566 F.3d 683, 686–87 (6th Cir. 2009) (per curiam) (citation omitted). The district

court “varied” upwards; it did not “depart.” So no Rule 32(h) violation occurred. See United

States v. Grigg, 434 F. App’x 530, 534 (6th Cir. 2011) (“Fed. R. Crim. P. 32(h) requires the district

court provide reasonable notice for departures under the sentencing guidelines, but not for

variances under § 3553(a).” (citing Irizarry, 553 U.S. at 716)).

At any rate, a sentence may be procedurally unreasonable when “the facts or issues on

which the district court relied to impose a variance came as a surprise and [the defendant’s]

presentation to the court was prejudiced by the surprise.” United States v. Coppenger, 775 F.3d

799, 804 (6th Cir. 2015) (quotation omitted). No such surprise occurred. The district court

informed the parties during the sentencing hearing that it was considering an upward variance and

then heard argument on that issue. The district court did not err, as Harp contends, by “not tell[ing]

the parties ahead of time that it was considering an upward variance based upon Mr. Harp’s prior

federal case.” D.

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