United States v. Jabrown Parks

CourtCourt of Appeals for the Sixth Circuit
DecidedJuly 14, 2023
Docket22-3678
StatusUnpublished

This text of United States v. Jabrown Parks (United States v. Jabrown Parks) 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. Jabrown Parks, (6th Cir. 2023).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 23a0322n.06

Case No. 22-3678

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

FILED Jul 14, 2023 ) UNITED STATES OF AMERICA, DEBORAH S. HUNT, Clerk ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE v. ) UNITED STATES DISTRICT ) COURT FOR THE NORTHERN JABROWN PARKS, DISTRICT OF OHIO ) Defendant-Appellant. ) OPINION )

Before: CLAY, GRIFFIN, and DAVIS, Circuit Judges.

DAVIS, Circuit Judge. Defendant-Appellant Jabrown Parks appeals his sentence for

supervised release violations as procedurally and substantively unreasonable. Parks served

substantial time in federal prison for bank robbery and brandishing a firearm during and in relation

to a crime of violence. After his release from custody and two years into his five-year term of

supervised release, Parks was arrested for attempting to rob a woman at gun point. While on bond

for that offense, he robbed another bank. He was tried and found guilty of the bank robbery in

state court and received a sentence of twenty-two years in prison. Parks subsequently admitted,

during a violation hearing in federal court, that he breached the terms of his supervised release.

As a result, the district court revoked his supervised release and imposed an above-Guidelines

sentence to be served consecutively to his state sentence. For the reasons that follow, we affirm. Case No. 22-3678, United States v. Parks

I.

In 2003 Parks and two others were indicted in the Southern District of Ohio in connection

with two bank robberies. Counts 1 and 2 of the indictment pertained to a September 2003 robbery

of U.S. Bank in Columbus, Ohio. And Counts 3 and 4 stemmed from a December 2003 robbery

of First Federal Savings and Loan in Pataskala, Ohio. Parks’s two co-defendants were charged in

all four counts, but he was charged only in the latter two. He pleaded guilty to Count 3 for armed

bank robbery of First Federal Savings and Loan and to Count 4 for brandishing a firearm during

the robbery. The district court sentenced Parks to 87 months on Count 3 and a consecutive term

of 84 months on Count 4, for a total of 171 months’ imprisonment, to be followed by concurrent

individual 5-year terms of supervised release on each count.

Parks began his supervised release period on May 27, 2016. About two years later, the

Southern District of Ohio transferred jurisdiction over his supervision to the Northern District of

Ohio. Shortly after the transfer, his probation officer filed a violation report with the court,

advising that Parks had violated his conditions of supervision by committing two new robbery-

related offenses in Ohio in May and July of 2018. As to the first offense, Parks had been arrested

and charged with attempting to rob a woman at gun point while she was opening her business for

the day in Cuyahoga County. No one could identify Parks as the suspect, but a witness saw the

suspect flee into a wooded area, and police apprehended Parks as he was exiting the same wooded

area moments after officers arrived on the scene. Parks posted bond but failed to appear at the

next scheduled court hearing. The case remained pending at the time of the violation report.

The second offense involved another bank robbery. Parks was tried by jury in state court

and convicted of robbing a Fifth Third Bank in Lake County. The evidence at trial showed that

Parks had entered the bank wearing a motorcycle helmet and carrying a gas can. He demanded

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money from an employee while waving the gas can and instructing the employee not to give him

any dye packs. After collecting the money, he fled the scene in a white Lexus. Authorities

discovered that the vehicle, which had subsequently been set on fire and abandoned, was registered

to Parks. Following the jury’s guilty verdict, the court sentenced him to 22 years’ imprisonment,

which he began serving in 2019. Accordingly, at the time of the violation report, Parks was serving

a 22-year sentence for the Lake County conviction and had another case pending against him in

Cuyahoga County.

On November 20, 2019, the district court held a hearing on the reported violations. The

court indicated that it would dismiss the violation relating to the pending Cuyahoga County case

as moot and hold further violation proceedings in abeyance to allow time for Parks to appeal his

Lake County conviction. The court held the next hearing on August 3, 2022, during which Parks

admitted to the violations arising from both robberies. The court found that he had violated the

conditions of his supervised release and imposed an above-Guidelines sentence of five years’

imprisonment to run consecutive to his state sentence. Parks objected to the district court’s upward

variance at the conclusion of the hearing. He now appeals.

II.

Standard of Review. This court typically reviews a district court’s sentencing

determinations for an abuse of discretion, irrespective of whether the sentence falls within or

outside the Guidelines range. Gall v. United States, 552 U.S. 38, 51 (2007). This includes

sentences for violations of supervised release. United States v. Adams, 873 F.3d 512, 516 (6th Cir.

2017). Sentences must be both procedurally and substantively reasonable. Id. When reviewing a

sentencing determination, we “must first ensure that the district court committed no significant

procedural error[.]” Gall, 552 U.S. at 51. To ensure that a sentence is procedurally sound, the

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district court must properly calculate the Guidelines range, treat the Guidelines as advisory,

consider the 18 U.S.C. § 3553(a) factors, select a sentence based on facts that are not clearly

erroneous, and adequately explain the sentence including any deviation from the Guidelines. Id.

If the sentence is procedurally sound, we then look to the totality of circumstances to determine

whether the sentence is substantively reasonable. In that vein, the sentence must be “sufficient,

but not greater than necessary, to comply with the purposes of sentencing.” Id. at 50 n. 6 (quoting

§ 3553(a) (internal quotation marks omitted)). Sentences within the Guidelines enjoy a

presumption of substantive reasonableness. United States v. Perez-Rodriguez, 960 F.3d 748, 754

(6th Cir. 2020). But the converse is not true; a sentence outside the Guidelines is not presumptively

unreasonable. United States v. Robinson, 813 F.3d 251, 264 (6th Cir. 2016). We still afford “due

deference” to a district court’s decision to vary from the Guidelines. Gall, 552 U.S. at 51.

Notably, because we “do not require defendants to challenge the ‘reasonableness’ of their

sentences in front of the district court,” an abuse-of-discretion standard will always apply to

challenges to the substantive reasonableness of a sentence. United States v. Vonner, 516 F.3d 382,

392 (6th Cir. 2008) (en banc). However, if a defendant does not challenge the procedural

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