United States v. Heil

CourtDistrict Court, D. Nevada
DecidedFebruary 13, 2025
Docket2:24-cv-01505
StatusUnknown

This text of United States v. Heil (United States v. Heil) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Heil, (D. Nev. 2025).

Opinion

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF NEVADA

3 UNITED STATES OF AMERICA, 4 Plaintiff/Appellee, Case No.: 2:24-cv-01505-GMN-NJK 5 vs. ORDER AFFIRMING MAGISTRATE 6 MELISSA HEIL, JUDGE’S SENTENCE 7 Defendant/Appellant. 8 9 Pending before the Court is the Notice of Appeal, (ECF No. 1), and the Amended Notice 10 of Appeal, (ECF No. 3), filed by Appellant Melissa Heil. Appellant filed an Opening Brief, 11 (ECF No. 6), Appellee filed a Response, (ECF No. 7), and Appellant replied, (ECF No. 9). 12 Because the Court finds that the Magistrate Judge did not abuse her discretion in sentencing 13 Heil to two years of supervised probation, the Court AFFIRMS the sentence and DENIES 14 Heil’s appeal. 15 I. BACKGROUND 16 This action arises from an appeal of Appellant Heil’s criminal sentencing in Case No. 17 2:22-mj-00941-NJK-1. (See generally Opening Brief, ECF No. 6). In May 2022, a ranger 18 working in the Lake Mead National Recreation area pulled Ms. Heil over as she was traveling 19 on Lake Mead Boulevard. (Presentence Report (“PSR”) ¶ 7, ECF No. 47 in 2:22-mj-00941- 20 NJK-1). The ranger smelled marijuana coming from the car and conducted a traffic stop. (Id.). 21 After noticing signs of impairment, the ranger discovered drugs and paraphernalia. (Id.). Heil 22 showed signs of impairment on the field sobriety test, and her blood draw indicated a presence 23 of THC and methamphetamine. (Id. ¶ 7, p. 2). Heil was charged with a DUI. (Id. at 4). 24 Over a year later, in September 2023, Heil was pulled over by a ranger in the Lake Mead 25 Recreation Area for speeding. (Id. ¶ 8). Heil’s minor child was in the car. (Id.). The ranger 1 noticed signs of impairment and conducted a field sobriety test, which Heil failed. (Id.). Heil’s 2 blood draw tested positive for marijuana, amphetamines, and methamphetamines. (Id.). Heil 3 was subsequently arrested. (Id.). 4 Heil later pled guilty to operating a motor vehicle while under the influence of drugs, in 5 violation of 36 C.F.R. § 4.23(a)(1), for both the 2022 and 2023 incidents. (Plea agreement, ECF 6 No. 45, in 2:22-mj-00941-NJK-1). As part of the plea deal, the government agreed to amend 7 the convictions to unsafe-operation convictions if Heil completed one year of supervised 8 probation, among other conditions. (Id. at 2, 3). Before sentencing, the Probation Office 9 recommended that she be sentenced to a three-year term of probation for each charge, to run 10 concurrently. (PSR ¶ 66). Magistrate Judge Koppe sentenced Heil to two concurrent two-year 11 terms of supervised probation. (See generally J., ECF No. 50, in 2:22-mj-00941-NJK-1). Heil 12 appeals that sentence, arguing that the Magistrate Judge abused her discretion in sentencing her 13 to a term of probation longer than the parties’ joint recommendation. (See generally Opening 14 Brief). 15 II. LEGAL STANDARD 16 When a defendant appeals a sentence imposed by a magistrate judge, the district court 17 judge considers the appeal “as though the appeal were to a court of appeals from a sentence 18 imposed by a district court.” 18 U.S.C.A. § 3742(h). Federal Rule of Criminal Procedure 58 19 allows criminal defendants to appeal a sentence imposed by a magistrate judge within 14 days,

20 but “[t]he defendant is not entitled to a trial de novo by the district judge.” Id. § 3742. The 21 Ninth Circuit directs the reviewing court to “first consider whether the [sentencing] court 22 committed procedural error, then [it] consider[s] the substantive reasonableness of the 23 sentence.” United States v. Apodaca, 641 F.3d 1077, 1080 (9th Cir. 2011) (quoting United 24 States v. Carty, 520 F.3d 984, 993 (9th Cir. 2008) (en banc)). 25 1 When, as here, the appellant appeals the substantive reasonableness of the sentence, the 2 reviewing court reviews the magistrate judge’s sentence for abuse of discretion. United States 3 v. Autery, 555 F.3d 864, 871 (9th Cir. 2009). “The abuse of discretion standard applies to all 4 sentencing decisions, whether the sentence is inside the [g]uidelines range or outside of it.” 5 Carty, 520 F.3d at 993. This deferential standard “should not resemble a de novo review” and 6 “provide[s] relief only in rare cases.” United States v. Ellis, 641 F.3d 411, 422 (9th Cir. 2011); 7 United States v. Ressam, 679 F.3d 1069, 1088 (9th Cir. 2012). In evaluating substantive 8 reasonableness, this Court looks to the “totality of the circumstances,” Carty, 520 F.3d at 993, 9 and reviews the district court’s factual findings for “clear error.” United States v. Armstead, 552 10 F.3d 769, 776 (9th Cir. 2008). 11 High deference is given to the sentencing court because “[t]he sentencing judge is in a 12 superior position to find facts and judge their import under § 3553(a) in the individual case.” 13 Gall v. United States, 552 U.S. 38, 51 (2007); accord United States v. Orlando, 553 F.3d 1235, 14 1238–39 (9th Cir. 2009) (“A district court’s discretion under the § 3553(a) factors is quite 15 broad.”). Moreover, “[t]he weight to be given the various factors in a particular case is for the 16 discretion of the district court.” United States v. Gutierrez-Sanchez, 587 F.3d 904, 908 (9th Cir. 17 2009) (cleaned up). Courts “uphold a district court determination that falls within a broad 18 range of permissible conclusions.” Kode v. Carlson, 596 F.3d 608, 612 (9th Cir. 2010). “Under 19 the abuse of discretion standard, we ask first whether the district court applied the correct legal

20 rule, and then determine whether the court’s application of the legal rule was either 21 (1) illogical, (2) implausible, or (3) without support in the record.” United States v. Robertson, 22 895 F.3d 1206, 1213 (9th Cir. 2018) (internal quotations omitted). 23 III. DISCUSSION 24 Appellant Heil presents three arguments that she alleges, coupled together, establish that 25 the Magistrate Judge abused her discretion when she went above the joint recommendation of 1 the parties and instead sentenced Ms. Heil to two years of supervised probation. The Court 2 takes up each argument in turn. 3 First, she argues that the Magistrate Judge did not have sufficient reason to go above the 4 plea agreement and joint recommendation of the parties. (Opening Brief at 12). While it is true 5 that “public policy strongly supports plea agreements,” United States v. Navarro-Botello, 912 6 F.2d 318, 321 (9th Cir. 1990), “[t]he sentencing court, of course, still has discretion to reject the 7 joint recommendation.” United States v. Quach, 302 F.3d 1096, 1101 (9th Cir. 2002). 8 Appellant Heil even acknowledges that it was Magistrate Judge Koppe’s “right” to impose a 9 greater sentence than recommended in the plea agreement. (Opening Brief at 5). As discussed 10 in more detail below, based on the record before her, the Magistrate Judge had a sufficient basis 11 for imposing a two-year term of supervision.

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Related

Gall v. United States
552 U.S. 38 (Supreme Court, 2007)
United States v. Apodaca
641 F.3d 1077 (Ninth Circuit, 2011)
United States v. Ellis
641 F.3d 411 (Ninth Circuit, 2011)
United States v. Truong Quang Quach
302 F.3d 1096 (Ninth Circuit, 2002)
United States v. Ressam
679 F.3d 1069 (Ninth Circuit, 2012)
United States v. Carty
520 F.3d 984 (Ninth Circuit, 2008)
United States v. Autery
555 F.3d 864 (Ninth Circuit, 2009)
United States v. Orlando
553 F.3d 1235 (Ninth Circuit, 2009)
Kode v. Carlson
596 F.3d 608 (Ninth Circuit, 2010)
United States v. Hugo Gutierrez-Sanchez
587 F.3d 904 (Ninth Circuit, 2009)
United States v. Denise Robertson
895 F.3d 1206 (Ninth Circuit, 2018)

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United States v. Heil, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-heil-nvd-2025.