United States v. Doris Foster

CourtCourt of Appeals for the Fourth Circuit
DecidedJuly 20, 2022
Docket20-7745
StatusUnpublished

This text of United States v. Doris Foster (United States v. Doris Foster) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth 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. Doris Foster, (4th Cir. 2022).

Opinion

USCA4 Appeal: 20-7745 Doc: 28 Filed: 07/20/2022 Pg: 1 of 6

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 20-7745

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

DORIS DENISE FOSTER,

Defendant - Appellant.

Appeal from the United States District Court for the Western District of North Carolina, at Asheville. Martin K. Reidinger, Chief District Judge. (1:09-cr-00013-MR-WCM-7)

Submitted: June 8, 2022 Decided: July 20, 2022

Before MOTZ and HARRIS, Circuit Judges, and FLOYD, Senior Circuit Judge.

Vacated and remanded by unpublished per curiam opinion.

ON BRIEF: Anthony Martinez, Federal Public Defender, Charlotte, North Carolina, Joshua B. Carpenter, Appellate Chief, FEDERAL DEFENDERS OF WESTERN NORTH CAROLINA, INC., Asheville, North Carolina, for Appellant. William T. Stetzer, Acting United States Attorney, Charlotte, North Carolina, Amy E. Ray, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Asheville, North Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 20-7745 Doc: 28 Filed: 07/20/2022 Pg: 2 of 6

PER CURIAM:

Doris Denise Foster appeals the district court’s order granting in part and denying

in part her motion for a sentence reduction under Section 404 of the First Step Act of 2018,

Pub. L. No. 115-391, 132 Stat. 5194. On appeal, Foster contends the district court clearly

erred in asserting it had previously found a drug weight of 2,902.43 grams of cocaine base

and procedurally erred in recalculating her Guidelines range under the First Step Act. She

also contends any finding that she was responsible for more than 2.8 kilograms would be

clearly erroneous. We vacate the district court’s order and remand for further proceedings.

Under § 404(b) of the First Step Act, a district court may “impose a reduced

sentence ‘as if’ the revised penalties for crack cocaine enacted in the Fair Sentencing Act

of 2010 were in effect at the time the offense was committed.” Concepcion v. United

States, No. 20-1650, 2022 WL 2295029, at *4 (U.S. June 27, 2022); see also United States

v. McDonald, 986 F.3d 402, 408–09 (4th Cir. 2021) (internal quotation marks omitted).

When imposing a new sentence under this statutory scheme, “a court does not simply adjust

the statutory minimum; it must also recalculate the Guidelines range.” Id. at 409 (internal

quotation marks omitted); see also Concepcion, 2022 WL 2295029, at *10. District courts

retain much discretion in these proceedings, and “the scope of the analysis is defined by

the gaps left from the original sentencing to enable the court to determine what sentence it

would have imposed under the Fair Sentencing Act in light of intervening circumstances.”

United States v. Lancaster, 997 F.3d 171, 175 (4th Cir. 2021).

We review a district court’s First Step Act § 404 proceedings for procedural and

substantive reasonableness. United States v. Collington, 995 F.3d 347, 358–61 (4th Cir.

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2021). Among other things, this reasonableness standard requires a district court to

“accurately recalculate the Guidelines sentence range.” Id. at 355.

To accurately recalculate the Guidelines range, a district court may need to make

additional findings and identify the attributable drug quantity with more precision than at

the original sentencing. Lancaster, 997 F.3d at 176; see also United States v. Peters, 843

F.3d 572, 578 (4th Cir. 2016). “Such findings cannot contradict earlier ones and must be

supported by the record.” Peters, 843 F.3d at 578. “A district court may ‘adopt[] the PSR’s

findings in toto’ as the factual basis for a sentencing decision so long as it clearly resolved

any factual disputes.” United States v. Burnley, 988 F.3d 184, 190 (4th Cir. 2021) (quoting

United States v. Walker, 29 F.3d 908, 911 (4th Cir. 1994)).

“We review factual determinations, like the quantity of drugs attributable to a

defendant for sentencing purposes, for clear error.” United States v. Mann, 709 F.3d 301,

304 (4th Cir. 2013). “[T]o the extent the record is unclear, we must defer to the sentencing

judge’s reasonable understanding of the record – and particularly his interpretation of his

own earlier findings.” Id. at 306. However, “we need not defer to the district court if its

interpretation of its own previous ruling cannot be squared with the facts presented.” Id.

(citing United States v. Henry, 538 F.3d 300, 304–06 (4th Cir. 2008) (where actual record

failed to support district court’s recollection, no deference accorded)).

We have reviewed the record and agree with Foster that the district court clearly

erred in asserting it previously found a drug weight of 2,902.43 grams of cocaine base, and

it procedurally erred in recalculating her Guidelines range under the First Step Act. At her

sentencing in 2010, the presentence report (PSR) recommended a drug weight of 2,902.43

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grams, but Foster objected. In response, the Government argued the evidence supported,

at minimum, a finding of more than 1.5 kilograms. In resolving the objection, the court’s

“finding of fact” was “that the amount of cocaine base reasonably foreseeable to the

defendant in this matter was in the range between 1.5 and 4.5 kilos”; and it therefore

accepted the base offense level and Guidelines calculations stated in the PSR and overruled

the objection on that basis. J.A. 46.

Moreover, in response to Foster’s argument at sentencing that the district court

should find her responsible for less than 2.8 kilograms, in anticipation of a retroactive

Guidelines amendment pursuant to the Fair Sentencing Act of 2010, the court explained

that this was one of the reasons that it adopted the range; and it indicated its intent to make

a more precise finding on drug weight in the event of a retroactive amendment. J.A. 65–

66.

On direct appeal, the parties agreed the district court at sentencing had found Foster

responsible for a range between 1.5 and 4.5 kilograms, and Foster argued the finding was

erroneous. We held the district court did not clearly err in that finding under the Guidelines

in effect at the time of sentencing, but our decision was “rendered without prejudice to

Foster’s right to pursue a sentence reduction in the district court pursuant to 18 U.S.C.

§ 3582(c)(2).” United States v. Foster, 452 F. App’x 274, 276 (4th Cir. 2011).

Although the district court subsequently granted Foster’s counseled motion under

18 U.S.C. § 3582(c)(2) for a sentence reduction based on Amendment 782, it appears the

probation officer in that proceeding erroneously represented that the court’s original drug-

quantity finding was 2,902.43 grams, and there was no objection to or correction of the

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error. Although we affirmed the district court’s subsequent order denying Foster’s pro se

motion for a further reduction, we specifically noted “that the district court’s finding of

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Related

United States v. Doris Foster
452 F. App'x 274 (Fourth Circuit, 2011)
United States v. Harold R. Walker
29 F.3d 908 (Fourth Circuit, 1994)
United States v. Robert Mann
709 F.3d 301 (Fourth Circuit, 2013)
United States v. Henry
538 F.3d 300 (Fourth Circuit, 2008)
United States v. Spencer Peters
843 F.3d 572 (Fourth Circuit, 2016)

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