United States v. Dextrick Lawton

CourtCourt of Appeals for the Third Circuit
DecidedNovember 25, 2025
Docket24-3322
StatusUnpublished

This text of United States v. Dextrick Lawton (United States v. Dextrick Lawton) 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. Dextrick Lawton, (3d Cir. 2025).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT

No. 24-3322

UNITED STATES OF AMERICA

v.

DEXTRICK LAWTON, Appellant

Appeal from the United States District Court for the Western District of Pennsylvania (District Court No. 2:12-cr-00295-001) District Judge: Honorable Marilyn J. Horan

Submitted under Third Circuit L.A.R. 34.1(a) November 13, 2025

Before: RESTREPO, McKEE, and AMBRO, Circuit Judges

(Opinion filed: November 25, 2025)

___________ OPINION* ___________ AMBRO, Circuit Judge

Defendant-Appellant Dextrick Lawton pled guilty in 2013 to conspiracy to

distribute and possess with intent to distribute heroin. Consistent with the plea agreement,

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. the District Court sentenced him to 15 years in prison to be followed by 5 years of

supervised release. On this appeal—his third—Lawton challenges the District Court’s

denial of his latest motion for a sentence reduction. On his last appeal, we affirmed the

finding he disputes and rejected the arguments he renews. We again affirm.

I.

In 2013, Lawton accepted a plea agreement per Federal Rule of Criminal Procedure

11(c)(1)(C) on charges of conspiracy to distribute and possess with intent to distribute

heroin. Initially, the Presentence Report (PSR) specified that he played a leadership role in

the conspiracy. But he objected to that finding and the District Court excised the offending

paragraphs. The Court then sentenced him as noted above. Lawton appealed, but we held

he had waived his appellate rights. United States v. Lawton, 640 F. App’x 146, 146–47 (3d

Cir. 2016).

A few years later, Lawton moved for a sentence reduction under 18 U.S.C. §

3582(c)(2) to avail himself of a retroactive amendment to the U.S. Sentencing Guidelines.

The District Court denied the motion, mainly on the ground that his agreement to a 15-year

sentence spared him charges with a mandatory minimum of 20 years imprisonment and the

possibility of a life sentence. However, the Court also asserted that “despite his age,

Defendant was found to have played a leadership role within the drug-trafficking

conspiracy.” United States v. Lawton, No. 12-295, 2020 WL 1935518, at *4 (W.D. Pa. Apr.

21, 2020). Lawton appealed, arguing the District Court gave undue weight to the plea

agreement and made the unsubstantiated finding that he had a leadership role in the

2 conspiracy. Lawton v. United States, No. 20-2118, 2020 WL 6319251, at *30, *34, *37–38

(3d Cir. Oct. 26, 2020). We affirmed. United States v. Lawton, 848 F. App’x 499, 502 (3d

Cir. 2021).

Last year, Lawton moved again for a sentence reduction because of a retroactive

amendment to the Guidelines, Amendment 821. The District Court determined that the

amendment retroactively changed how “status points” determine a defendant’s criminal

history category. Before, Lawton’s criminal history category was a III and his Guidelines

range was 151 to 188 months; now, his history category would be a II and his range would

be 120 to 135 months. Nonetheless, the District Court determined the 18 U.S.C. § 3553(a)

factors did not warrant reducing Lawton’s sentence, primarily because, as noted before, his

plea agreement spared him the risk of a much longer one. The District Court also repeated

the leadership role finding from the prior opinion.

Lawton appeals.

II.

We have jurisdiction under 28 U.S.C. § 1291 and 18 U.S.C. § 3742(a). We review

the denial of a § 3582(c)(2) motion for abuse of discretion, save for “purely legal

question[s],” which are subject to plenary review. United States v. Ware, 694 F.3d 527, 531

(3d Cir. 2012). A district court abuses its discretion only if we have a “definite and firm

conviction” that the court “committed a clear error of judgment in the conclusion it reached

upon a weighing of the relevant factors.” Oddi v. Ford Motor Co., 234 F.3d 136, 146 (3d

Cir. 2000).

3 III.

When the Sentencing Commission retroactively lowers the range under which a

defendant was sentenced, he may move for a sentence reduction under 18 U.S.C. §

3582(c)(2). See Dillon v. United States, 560 U.S. 817, 824–25 (2010). The inquiry has two

steps. Id. at 827. At step one, the district court must “determin[e] the amended guideline

range that would have been applicable to the defendant had the relevant amendment been

in effect at the time of the initial sentencing.” Id. (cleaned up). At step two, the court must

consider “any applicable § 3553(a) factors and determine whether, in its discretion, the

reduction authorized by reference to the policies relevant at step one is warranted . . . under

the particular circumstances of the case.” Id. This appeal concerns only the District Court’s

step two determination that the § 3553(a) factors did not warrant a shorter sentence.

Lawton argues the District Court violated due process when it considered his alleged

leadership role in the offense despite the initial sentencing court’s excision of the relevant

portion of the PSR. The Court denied his first motion for a sentence reduction in part on

this same dubious basis. Compare United States v. Lawton, No. 12-295, 2020 WL 1935518,

at *4 (W.D. Pa. Apr. 21, 2020) (“Moreover, despite his age, Defendant was found to have

played a leadership role within the drug-trafficking conspiracy.”) with Appx 11 (“Further,

despite his age, Defendant was found to have played a leadership role within that

conspiracy.”). On appeal, Lawton challenged it on the same due process basis he does now.

Brief for Appellant, Lawton, 2020 WL 6319251, at *30, *34, *37–38. We affirmed, finding

“the District Court correctly focused upon the benefits the plea agreement conferred upon

4 Lawton,” and brushing aside his other “constitutional and statutory arguments” as

“lack[ing] merit.” Lawton, 848 F. App’x at 502.

That makes the propriety of the leadership role holding the law of the case. The

doctrine for law of the case “holds that a rule of law announced in a case should later be

applied to the same issues in subsequent stages in the litigation.” United States v. Jackson,

132 F.4th 266, 276 (3d Cir. 2025) (quotation omitted). We will reconsider the propriety of

the leadership role finding only under “extraordinary circumstances,” such as the discovery

of new evidence, the announcement of supervening law, or the determination “the earlier

decision was clearly erroneous and would create manifest injustice.” Pub. Int. Rsch. Grp.

of N.J., Inc. v. Magnesium Elektron, Inc., 123 F.3d 111, 116–17 (3d Cir. 1997).

Lawton does not point to new evidence or law. The leadership role finding may well

have been clearly erroneous.

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Related

Dillon v. United States
560 U.S. 817 (Supreme Court, 2010)
United States v. Andre Ware
694 F.3d 527 (Third Circuit, 2012)
Oddi v. Ford Motor Co.
234 F.3d 136 (Third Circuit, 2000)
United States v. Dextrick Lawton
640 F. App'x 146 (Third Circuit, 2016)
United States v. Carolyn Jackson
132 F.4th 266 (Third Circuit, 2025)

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