United States v. Hewitt

CourtCourt of Appeals for the Fifth Circuit
DecidedFebruary 5, 2021
Docket20-50297
StatusUnpublished

This text of United States v. Hewitt (United States v. Hewitt) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth 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. Hewitt, (5th Cir. 2021).

Opinion

Case: 20-50297 Document: 00515734603 Page: 1 Date Filed: 02/05/2021

United States Court of Appeals for the Fifth Circuit United States Court of Appeals Fifth Circuit

FILED February 5, 2021 No. 20-50297 Lyle W. Cayce Summary Calendar Clerk

United States of America,

Plaintiff—Appellee,

versus

Dexter Darnell Hewitt, also known as Dexter Curnell Hewitt,

Defendant—Appellant.

Appeal from the United States District Court for the Western District of Texas USDC No. 6:07-CR-149

Before Clement, Higginson, and Engelhardt, Circuit Judges. Per Curiam:* Defendant-Appellant, Dexter Darnell Hewitt, appeals the district court’s denial of his motion for sentence reduction filed pursuant to section 404 of the First Step Act of 2018, Pub. L. 115-391, § 404, 132 Stat. 5194–249

* Pursuant to 5th Circuit Rule 47.5, the court has determined that this opinion should not be published and is not precedent except under the limited circumstances set forth in 5th Circuit Rule 47.5.4. Case: 20-50297 Document: 00515734603 Page: 2 Date Filed: 02/05/2021

No. 20-50297

(2018). The First Step Act allows defendants who were convicted and sentenced for certain offenses involving cocaine base (“crack”), prior to the effective date of the Fair Sentencing Act of 2010, to be resentenced as if the reduced statutory minimum penalties implemented by the Fair Sentencing Act were in place at the time the offenses were committed. On January 7, 2009, Hewitt was sentenced to serve 236 months imprisonment based on a sentencing guidelines range of 210–262 months. Section 404 gives courts the discretion to retroactively apply the Fair Sentencing Act to reduce a prisoner’s sentence for certain covered offenses. United States v. Hegwood, 934 F.3d 414, 418 (5th Cir.), cert. denied, 140 S. Ct. 285 (2019) (“It is clear that the First Step Act grants a district judge limited authority to consider reducing a sentence previously imposed.”). The district court’s decision whether to reduce a sentence pursuant to the First Step Act is generally reviewed for an abuse of discretion. United States v. Stewart, 964 F.3d 433, 435 (5th Cir. 2020); United States v. Jackson, 945 F.3d 315, 319 & n.2 (5th Cir. 2019), cert. denied, 140 S. Ct. 2699 (2020). It is the defendant’s burden to “show that the trial judge's action amounted to an . . . abuse of discretion.” United States v. Garcia, 693 F.2d 412, 415 (5th Cir. 1982). “A court abuses its discretion when the court makes an error of law or bases its decision on a clearly erroneous assessment of the evidence.” United States v. Larry, 632 F.3d 933, 936 (5th Cir. 2011) (internal quotation marks and citation omitted). “[T]o the extent the court’s determination turns on the meaning of a federal statute such as the [First Step Act],” de novo review applies. Jackson, 945 F.3d at 319 (internal quotation marks and citation omitted). On appeal, Hewitt challenges the district court’s refusal to consider the lower, non-career offender sentencing range that would apply if he were sentenced in 2020, rather than in 2009, in deciding whether to grant his First Step Act motion for sentence reduction. In support of his position, Hewitt

2 Case: 20-50297 Document: 00515734603 Page: 3 Date Filed: 02/05/2021

contends that the district court erroneously interpreted Hegwood to “bar[] it from considering the fact that [he] no longer qualifies as a career offender under current law,” yielding a resulting non-career offender guidelines imprisonment range of only 63 to 78 months, rather than the 210–262 months associated with his career offender status. Finding no abuse of discretion or legal deficiency in the district court’s ruling, we AFFIRM. Certain of our recent decisions discuss the background and mechanics of the First Step Act at length. See United States v. Batiste, 980 F.3d 466 (5th Cir. 2020); United States v. Robinson, 980 F.3d 454 (5th Cir. 2020); United States v. Carr, 823 F. App’x 252 (5th Cir. 2020). Thus, it is unnecessary to repeat that exercise here. Having considered those principles, however, we are not persuaded that any legal error occurred in the district court’s assessment of Hewitt’s motion. Specifically, we are not convinced that the district court based its determination on an erroneous interpretation of the First Step Act, or any of our decisions interpreting the statute. Instead, as we concluded in our recent decisions in Batiste, Robinson, and Carr, it is more plausible, on the record before us, that the district court, having evaluated all pertinent factors, simply exercised its statutory discretion to deny the motion. Nor are we convinced that the district court abused that discretion. Having confirmed that Hewitt’s original sentence of 236 months does not exceed the amended statutory maximum of 40 years imprisonment applicable under § 2 of the Fair Sentencing Act, see 21 U.S.C. §§ 841(b)(1)(C) and 860(a), the district court explained its decision: Hewitt was a career offender under the sentencing guidelines. Pursuant to §4B1.1, Hewitt’s offense level was determined not by the quantity of drugs he possessed, but by his criminal history. Hewitt stood convicted of a controlled substance and had at least two prior convictions of either a crime of violence or a controlled substance offense. U.S.S.G.

3 Case: 20-50297 Document: 00515734603 Page: 4 Date Filed: 02/05/2021

§4B1.1 (a). Because the statutory maximum for his offense was 25 years or more, his offense level was automatically set at 34. U.S.S.G. §4B1.1 (b). A career offender’s criminal history category is always VI, regardless of the number of points a particular defendant may have. U.S.S.G. §4B1.1 (b). The application of the Fair Sentencing Act to Hewitt’s case did not change his guideline range in any manner—his original range remains 262 to 327 months imprisonment. Hewitt asserts that he would not be a career offender under the current state of the law because his prior drug convictions no longer qualify as predicate offenses, citing United States v. Tanksley, 848 F.3d 347 (5th Cir. 2017) and United States v. Hinkle, 832 F.3d 569 (5th Cir. 2016)[,] and he would be facing a much lower sentence today. Hewitt is a career offender—that designation, as Hewitt acknowledges, cannot be revisited. To do so would “encompass a broad resentencing rather than a reduction solely based on the Fair Sentencing Act.” Hegwood, 934 F.3d at 417. If Hewitt’s designation as a career offender could be viewed in the manner that he wishes, he would be subject to an upward departure under any version of the guidelines, U.S.S.G. §4A1.3, or a variance based on the 18 U.S.C. §3553(a) factors. The Court must therefore decide whether to exercise its discretion and reduce Hewitt’s sentence. The facts underlying his original sentence are certainly not helpful to Hewitt.

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Related

United States v. Christopher Larry
632 F.3d 933 (Fifth Circuit, 2011)
United States v. Reynaldo Garcia
693 F.2d 412 (Fifth Circuit, 1982)
United States v. Wayland Hinkle
832 F.3d 569 (Fifth Circuit, 2016)
United States v. Dantana Tanksley
848 F.3d 347 (Fifth Circuit, 2017)
United States v. Michael Hegwood
934 F.3d 414 (Fifth Circuit, 2019)
United States v. Odis Jackson
945 F.3d 315 (Fifth Circuit, 2019)
United States v. Jamie Stewart
964 F.3d 433 (Fifth Circuit, 2020)
United States v. Rexdual Robinson
980 F.3d 454 (Fifth Circuit, 2020)
United States v. Kojak Batiste
980 F.3d 466 (Fifth Circuit, 2020)

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Bluebook (online)
United States v. Hewitt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-hewitt-ca5-2021.