United States v. Lacarubba

184 F. Supp. 2d 89, 2002 U.S. Dist. LEXIS 4364, 2002 WL 77205
CourtDistrict Court, D. Massachusetts
DecidedJanuary 4, 2002
Docket1:01-cv-10033
StatusPublished
Cited by7 cases

This text of 184 F. Supp. 2d 89 (United States v. Lacarubba) is published on Counsel Stack Legal Research, covering District Court, D. Massachusetts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Lacarubba, 184 F. Supp. 2d 89, 2002 U.S. Dist. LEXIS 4364, 2002 WL 77205 (D. Mass. 2002).

Opinion

SENTENCING MEMORANDUM

GERTNER, District Judge.

This case raises questions concerning the status of sentencing departures in the First Circuit for “extraordinary family obligations” (under U.S.S.G. § 5H1.6) in the wake of two recent decisions, United States v. Pereira, 272 F.3d 76 (1st Cir.2001) and United States v. Thompson, 234 F.3d 74 (1st Cir.2000).

In Thompson, the Court held that it was error when a trial court, seeking to determine if a departure for family obligations was warranted, compared the defendant to other defendants similarly situated with respect to the offense of conviction. Although the trial court based its decision on the express language of the. Sentencing Reform Act (“SRA”), 1 the Guidelines, 2 and the scholarly commentary, 3 the Court disagreed, holding that the proper approach is to compare any given defendant to all defendants regardless of offense.

In Pereira, the Court held that a defendant must be found to be “irreplaceable” to his or her family before the Court can depart downward under this section. It noted that its decision was “nothing more than a distillation of existing judicial principles,” 272 F.3d at 83, notwithstanding the fact that prior First Circuit cases, and sentences by trial judges within this dis *91 trict and other jurisdictions, seemed to permit downward departures in a variety of situations short of “irreplaeeability.”

Putting the two cases together, then, as I am obliged to do, the law of the First Circuit is as follows: Before a court in the District of Massachusetts can depart downward for “extraordinary family obligations” the trial court must measure the defendant against all other defendants, no matter the crime of his or her conviction, and determine whether he or she is “irreplaceable.”

I have, and the defendant in this ease, Paul LaCarubba, is.

Mr. LaCarubba has pled guilty to an information charging two counts of tax evasion, in violation of 26 U.S.C. § 7201. The guideline range, without departure, was 18 to 24 months, with the parties’ plea agreement recommending sentencing at the low end. 4 But after the plea agreement was signed, Mr. LaCarubba found out that his wife of thirty years had terminal liver cancer, a particularly virulent form of the disease. 5 Fewer than 20% of such individuals are alive within five years.

Mr. LaCarubba’s role in his wife’s care is critical. He administers chemotherapy injections to her in her groin. Expert material presented at sentencing suggests that while strangers may be paid to be caretakers, a husband is in a unique position to minister to his wife. Her mental health and even the duration of her survival, limited though it may be, is at stake. If anyone is irreplaceable to Ms. LaCarubba, it is Mr. LaCarubba..

The principle I applied was simple: While Mr. LaCarubba deserved to be punished, his wife did not. Assuming the law allows for the humane concern for others, which I do, I departed downward three levels, from a level 13 to a level 10, and sentenced Mr. LaCarubba to three years’ probation. In order to punish Mr. LaCa-rubba, I required him to spend one year in home confinement, with electronic monitoring, and to pay a substantial fine of $10,000.

I. FRAMEWORK FOR ANALYSIS

While it is popular to stress one goal of the Sentencing Reform Act, uniformity, to the exclusion of all others, in fact the drafters endorsed other sentencing goals— notably, proportionality. 6 In its introduc *92 tion, the Commission described the difficulties of creating guidelines that met both goals. Too much uniformity would create a system easy to administer but would threaten proportionality, while a guideline system that accounted for every conceivable relevant offender and offense characteristic would destroy uniformity and surely be unworkable. U.S.S.G. § 1A.4(b); 1A.3. 7

The Sentencing Guidelines were the compromise. In the interest of uniformity, the Commission created guidelines that purported to take into account many factors relating to the offense, the offender’s criminal history, and to a lesser degree, other offender characteristics. In the interest of proportionality, the Commission gave courts the discretion to depart from the guideline sentence when additional factors existed that made the case unusual. 8 The Commission itself noted that “it is difficult to prescribe a single set of guidelines that encompass the vast range of human conduct potentially relevant to a sentencing decision.” 9 As a general matter, the Commission used the idea of “heartland” to distinguish between the “typical” cases, which should be sentenced uniformly, according to the Guidelines, and those “atypical” cases for which a departure is warranted. 10

Departures were not “violations” of the Guidelines, but rather part and parcel of its goals and the Guidelines’ evolution. Indeed, recognizing that departures would necessarily lead to differences in sentencing between similarly situated offenders, the Congress spoke of “unwarranted” disparities. 11 Departures grounded in the atypical facts of the individual case were “warranted.”

In the case of family ties, the statute directed the Commission to “assure that the guidelines ... reflect the general inappropriateness” of this factor to sentencing. 28 U.S.C. § 994(e). Specifically, the Commission translated this directive into the policy guideline that family ties are “not ordinarily relevant.” U.S.S.G. § 5H1.6.

But the Commission’s language is far from clear. While other guidelines — what the base offense level is for a given quantity of drugs, for example — are precise, this guideline is vague. While other guidelines provide an elaborate rationale or even spe *93 cific examples, 12 this guideline does not.

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Bluebook (online)
184 F. Supp. 2d 89, 2002 U.S. Dist. LEXIS 4364, 2002 WL 77205, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-lacarubba-mad-2002.