United States v. Joseph Long

CourtCourt of Appeals for the Third Circuit
DecidedFebruary 13, 2024
Docket23-1215
StatusUnpublished

This text of United States v. Joseph Long (United States v. Joseph Long) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third 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. Joseph Long, (3d Cir. 2024).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ________________

No. 23-1215 ________________

UNITED STATES OF AMERICA

v.

JOSEPH C. LONG,

Appellant ________________

Appeal from the United States District Court for the District of New Jersey (D.C. Criminal No. 1-21-cr-00493-001) District Judge: Honorable Joseph H. Rodriguez ________________

Submitted under Third Circuit LAR 34.1(a) on November 1, 2023

Before: JORDAN, ROTH and AMBRO, Circuit Judges

(Opinion filed: February 13, 2024) ________________

OPINION * ________________

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. ROTH, Circuit Judge

Joseph Long pleaded guilty to one count of possession with intent to distribute

cocaine. The District Court applied several enhancements to his sentence, including the

“Career Offender” and “Stash House” enhancements, resulting in a sentencing range of

168 to 210 months’ imprisonment under the United States Sentencing Guidelines. It then

sentenced Long to 156 months’ imprisonment. It correctly applied the Career Offender

enhancement, and any error in the application of the Stash House enhancement was

harmless in this case. We will, therefore, affirm the judgment of sentence.

I. BACKGROUND

On January 15, 2020, police officers searched Long’s apartment and his mother’s

residence. During the search of Long’s apartment, officers seized cocaine and other drug-

trafficking paraphernalia. During the search of his mother’s residence, officers seized

cocaine, heroin, marijuana, drug paraphernalia, firearms, and cash. On March 24, 2022,

Long pleaded guilty to possession with intent to distribute cocaine in violation of 21 U.S.C.

§§ 841(a)(1) and (b)(1)(c).

Long faced a statutory maximum sentence of 20 years’ imprisonment. After

accounting for his previous state felony convictions, 1 the presentence investigation report

(PSR) calculated the applicable sentence range under the Guidelines as 168 to 210 months.

The District Court considered the 18 U.S.C. § 3553(a) factors and sentenced Long to 156

1 These include New Jersey state felony convictions for aggravated assault, distribution of marijuana, and distribution of heroin. 2 months’ imprisonment followed by a three-year term of supervised release, slightly below

the Guidelines range.

The District Court applied two sentencing enhancements at issue here. First, it

applied the Career Offender enhancement under U.S.S.G. § 4B1.1(b)(2) based on Long’s

prior state convictions. Second, it applied the Stash House enhancement under U.S.S.G. §

2D1.1(b)(12) because Long “maintained a premises for the purpose of manufacturing or

distributing a controlled substance.” 2 Long appeals the District Court’s application of these

two enhancements.

II. JURISDICTION AND STANDARD OF REVIEW

The District Court had jurisdiction under 18 U.S.C. § 3231. We have jurisdiction

under 28 U.S.C. § 1291 and 18 U.S.C. § 3742(a). We review legal interpretation of the

Guidelines de novo 3 and findings of fact for clear error. 4 Applications of sentencing

enhancements are also subject to harmless error review. 5

III. ANALYSIS

Long first challenges the District Court’s application of the two-level Stash House

enhancement under U.S.S.G. § 2D1.1(b)(12). For the enhancement to apply, the

government must prove by a preponderance of the evidence that a defendant maintained

2 U.S.S.G. § 2D1.1(b)(12). 3 United States v. Upshur, 67 F.4th 178, 180 (3d Cir. 2023); United States v. Nasir, 17 F.4th 459, 468 (3d Cir. 2021) (en banc). 4 United States v. Rodriguez, 40 F.4th 117, 120 (3d Cir. 2022). 5 Even if a district court misapplies the Guidelines, remand is inappropriate when we “conclude[], on the record as a whole, that the error was harmless[.]” Williams v. United States, 503 U.S. 193, 203 (1992) (citing Fed. R. Crim. P. 52(a)). 3 his residence for the purpose of distributing drugs. 6 A defendant does not maintain a

residence “for the purpose” of drug-trafficking under Section 2D1.1(b)(12) where the drug

distribution activities were only an incidental or collateral use of the residence. 7 Long

argues that the drug distribution activities at his apartment were minimal and that he

principally used his car and his mother’s residence instead. The District Court, however,

found that Long’s use of his own apartment for drug-distribution was more than “incidental

or collateral.” Even if that finding was in error—and we do not suggest that it was—any

error was nonetheless harmless.

When a sentencing enhancement is wrongly applied, that error is harmless if it “did

not affect the [] court’s selection of the sentence imposed.” 8 An important consideration

in harmless error review is whether the enhancement at issue had any bearing on the

Guideline range applicable to the petitioner. 9 Here, the Stash House enhancement did not

affect the Guidelines range because the District Court separately applied the Career

Offender enhancement. That enhancement alone resulted in a total offense level of 30,

6 United States v. Carter, 834 F.3d 259, 261 (3d Cir. 2016). 7 U.S.S.G. § 2d1.1, cmt. n.17 (“Manufacturing or distributing a controlled substance need not be the sole purpose for which the premises was maintained, but must be one of the defendant’s primary or principal uses for the premises, rather than one of the defendant’s incidental or collateral uses for the premises.”). 8 Williams v. United States, 503 U.S. 193, 203 (1992) (citing Fed. R. Crim. P. 52(a)). 9 See, e.g., United States v. Perez-Colon, 62 F.4th 805, 817 (3d Cir. 2023) (“Although the District Court should not have applied the § 4B1.5(b) enhancement, we hold its error was harmless, largely because it did not affect [petitioner’s] advisory Guidelines range.”); accord United States v. Hollow, 208 F.3d 218, 2000 WL 307266, at *1 (8th Cir. 2000) (unpublished table decision) (finding harmless error because “[w]ith or without the challenged enhancement, [petitioner’s] offense level would have been [the same] because he was a career offender”). 4 even accounting for a two-level downward departure for Long’s acceptance of

responsibility. Meanwhile, the Stash House enhancement would have only raised the

applicable offense level from 24 to 26.

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

Related

Williams v. United States
503 U.S. 193 (Supreme Court, 1992)
United States v. Elmer Gomez-Alvarez
781 F.3d 787 (Fifth Circuit, 2015)
United States v. Kenneth Carter
834 F.3d 259 (Third Circuit, 2016)
United States v. Townsend
897 F.3d 66 (Second Circuit, 2018)
United States v. Nathaniel Ruth
966 F.3d 642 (Seventh Circuit, 2020)
United States v. Timothy Ward
972 F.3d 364 (Fourth Circuit, 2020)
United States v. Isaac Bautista
989 F.3d 698 (Ninth Circuit, 2021)
United States v. Isaiah Henderson
11 F.4th 713 (Eighth Circuit, 2021)
United States v. Malik Nasir
17 F.4th 459 (Third Circuit, 2021)
United States v. Gimy Rodriguez
40 F.4th 117 (Third Circuit, 2022)
United States v. Jamar Lewis
58 F.4th 764 (Third Circuit, 2023)
United States v. Justyn Perez-Colon
62 F.4th 805 (Third Circuit, 2023)
United States v. Albert Upshur
67 F.4th 178 (Third Circuit, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Joseph Long, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-joseph-long-ca3-2024.