United States v. Joel G. Audain

CourtCourt of Appeals for the Eleventh Circuit
DecidedJuly 24, 2018
Docket15-13217
StatusUnpublished

This text of United States v. Joel G. Audain (United States v. Joel G. Audain) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh 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. Joel G. Audain, (11th Cir. 2018).

Opinion

Case: 15-13217 Date Filed: 07/24/2018 Page: 1 of 8

[DO NOT PUBLISH]

IN THE UNITED STATES COURT OF APPEALS

FOR THE ELEVENTH CIRCUIT ________________________

No. 15-13217 ________________________

D.C. No. 0:97-CR-06007-FAM-16

UNITED STATES OF AMERICA,

Plaintiff-Appellee,

versus

JOEL G. AUDAIN, a.k.a. New Chief,

Defendant-Appellant.

________________________

Appeal from the United States District Court for the Southern District of Florida ________________________

(July 24, 2018) Case: 15-13217 Date Filed: 07/24/2018 Page: 2 of 8

Before ED CARNES, Chief Judge, MARCUS and EBEL, ∗ Circuit Judges.

PER CURIAM:

Defendant Joel Audain appeals the district court’s decision to deny his

motion for a reduced sentence under 18 U.S.C. § 3582(c)(2). Because the district

court relied on an improper factual finding to deny § 3582(c)(2) relief, we vacate

the district court’s decision and remand for further proceedings.

I. BACKGROUND

In 1998, a jury convicted Audain, a former Immigration and Naturalization

Service (“INS”) officer, of 1) conspiracy to import cocaine; 2) conspiracy to

possess cocaine with the intent to distribute it; 3) conspiracy to launder money; and

4) engaging in monetary transactions in property derived from specified unlawful

activity. At sentencing, the district court calculated Audain’s base offense to be

38, after finding Audain’s criminal conduct involved at least 150 kilograms of

cocaine. That was, at that time, the highest base offense available for his drug-

trafficking crimes based on type and amount of drugs involved. See U.S.S.G.

§ 2D1.1(c)(1) (1998). The court increased that base offense level of 38 by two

levels after finding Audain had abused a position of trust, and by another two

levels because he used a firearm during his drug-trafficking offenses. Important

for our purposes here, although the presentence report (“PSR”) suggested adding

∗ The Honorable David M. Ebel, Senior United States Circuit Judge for the United States Court of Appeals for the Tenth Circuit, sitting by designation. 2 Case: 15-13217 Date Filed: 07/24/2018 Page: 3 of 8

yet another two levels for obstruction of justice, the district court found at

sentencing that that enhancement did not apply to Audain.1

The sentencing court thus calculated Audain’s total offense level to be 42.

Combined with his criminal history category I, that offense level resulted in an

advisory range of 360 months to life in prison. The district court imposed

concurrent life sentences for each of Audain’s two drug-trafficking convictions—at

the top of the advisory imprisonment range—because Audain, as a law

enforcement officer who abused his position, “deserves a higher punishment”

(Doc. 985 at 76-77). 2

A number of years later, the U.S. Sentencing Commission amended

U.S.S.G. § 2D1.1, see U.S.S.G. App. C., Amdt. 782 (effective Nov. 1, 2014), to

“reduce[] the base offense level by two levels for most drug offenses,” Hughes v.

United States, 138 S. Ct. 1765, 1774 (2018). Relevant here, Amendment 782 made

offenses involving at least 150 kilograms but less than 450 kilograms of cocaine

1 The PSR recommended the obstruction-of-justice enhancement based on the PSR’s assertion that 1) Audain, as an INS officer, used his access to information about ongoing criminal investigations to help his co-defendant escape capture; and 2) transferred money Audain obtained from drug-trafficking to foreign bank accounts and then falsely stated on his U.S. tax returns that he had no foreign bank accounts. Audain objected to both bases for the obstruction-of-justice enhancement, claiming there was no evidence to support either. The district court found the enhancement did not apply, without further explanation. 2 The district court further sentenced Audain to the statutory maximum twenty years in prison for the money laundering conspiracy conviction and ten years for engaging in the relevant monetary transactions, each of these sentences to run concurrently with each other and with Audain’s concurrent life sentences on the drug-trafficking counts. See 18 U.S.C. §§ 1956(a)(1), (h); 1957(a), (b)(1). These sentences are not being challenged on appeal. 3 Case: 15-13217 Date Filed: 07/24/2018 Page: 4 of 8

subject to a lower base offense of 36, and offenses involving 450 kilograms or

more of cocaine to warrant an offense level of 38, still the highest base offense

level provided by § 2D1.1(c). This differed, then, from former § 2D1.1(c) as it

existed when Audain was sentenced in 1998, when any offense involving more

than 150 kilograms of cocaine warranted the highest base offense level, 38.

II. PROCEDURAL POSTURE

The Sentencing Commission made Amendment 782 retroactive. See U.S.

Sentencing Guidelines Manual App. C., Amdt. 788 (effective Nov. 1, 2014); see

also U.S.S.G. § 1B1.10(a), (d), (e). Three months later, Audain, acting pro se,

sought to reduce his sentence under 18 U.S.C. § 3582(c)(2). After eventually

considering arguments from both sides, the district court entered an order, on July

8, 2015, finally denying Audain § 3582(c)(2) relief. In doing so, the district court

stated: “Even if the defendant were eligible for a reduction of sentence, the Court

in its discretion denies it primarily because of the defendant’s status as a law

enforcement officer, his abuse of trust and his obstruction of justice.” (Doc. 1345.)

Audain timely appealed from that final decision and adequately identified

the orders he was challenging on appeal. See Nichols v. Ala. State Bar, 815 F.3d

726, 730-31 (11th Cir. 2016) (per curiam). We have jurisdiction to consider this

4 Case: 15-13217 Date Filed: 07/24/2018 Page: 5 of 8

appeal under 28 U.S.C. § 1291. This court appointed counsel to represent Audain

on appeal. 3

III. AUDAIN’S § 3582(c)(2) MOTION FOR A REDUCED SENTENCE

Ordinarily a district court “may not modify a term of imprisonment once it

has been imposed[.]” 18 U.S.C. § 3582(c); see also Dillon v. United States, 560

U.S. 817, 819 (2010). But Congress has provided several limited exceptions,

including § 3582(c)(2), which provides that,

in the case of a defendant who has been sentenced to a term of imprisonment based on a sentencing range that has subsequently been lowered by the Sentencing Commission pursuant to 28 U.S.C. 994(o), upon motion of the defendant or the Director of the Bureau of Prisons, or on its own motion, the court may reduce the term of imprisonment, after considering the factors set forth in section 3553(a) to the extent that they are applicable, if such a reduction is consistent with applicable policy statements issued by the Sentencing Commission.

Applying § 3582(c)(2), then, requires a two-part analysis, see Dillon, 560

U.S. at 826-27: First, the court must determine whether application of the

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Bravo
203 F.3d 778 (Eleventh Circuit, 2000)
United States v. Jules
595 F.3d 1239 (Eleventh Circuit, 2010)
Dillon v. United States
560 U.S. 817 (Supreme Court, 2010)
United States v. Maurice LaShane Hamilton
715 F.3d 328 (Eleventh Circuit, 2013)
W. David Nichols v. Alabama State Bar
815 F.3d 726 (Eleventh Circuit, 2016)
Hughes v. United States
584 U.S. 675 (Supreme Court, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Joel G. Audain, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-joel-g-audain-ca11-2018.