United States v. Larry Crump

CourtCourt of Appeals for the Sixth Circuit
DecidedOctober 14, 2022
Docket22-5073
StatusUnpublished

This text of United States v. Larry Crump (United States v. Larry Crump) 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. Larry Crump, (6th Cir. 2022).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 22a0408n.06

No. 22-5073

UNITED STATES COURT OF APPEALS FILED FOR THE SIXTH CIRCUIT Oct 14, 2022 DEBORAH S. HUNT, Clerk ) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE UNITED ) STATES DISTRICT COURT FOR v. ) THE EASTERN DISTRICT OF ) KENTUCKY LARRY A. CRUMP, ) Defendant-Appellant. ) OPINION )

Before: SUTTON, Chief Judge; STRANCH and DAVIS, Circuit Judges.

JANE B. STRANCH, Circuit Judge. Larry Crump appeals his sentence totaling 234

months’ imprisonment. The district court sentenced Crump within the relevant guideline range,

but Crump challenges the substantive reasonableness of his sentence, arguing the district court

failed to properly account for his mental health conditions in weighing the factors set forth in

18 U.S.C. § 3553(a). Because Crump’s sentence was substantively reasonable, we AFFIRM the

district court’s judgment.

I. BACKGROUND

In the span of four days in November 2020, appellant Larry Crump robbed a check-cashing

business and a bank in Mount Sterling, Kentucky. On both occasions, Crump displayed a handgun

to an employee and demanded money. All told, Crump absconded with approximately $37,900

cash. Crump was arrested, and authorities recovered approximately $25,000 of the stolen cash

from his uncle’s house. The Government indicted Crump on the following five counts in the No. 22-5073, United States v. Crump

Eastern District of Kentucky: (1) interference with commerce by threat or violence; (2) possession

of a firearm in furtherance of a violent offense; (3) bank robbery; (4) possession of a firearm in

furtherance of a violent offense; and (5) possession of a firearm by a convicted felon.

After arraignment, Crump’s counsel moved for a competency evaluation, noting Crump’s

history of “attempts at self-harm that have required medical intervention,” including an attempt

while in custody. The Government did not object. On October 6, 2021, a magistrate judge

conducted a competency hearing and, in line with the prepared competency report, found that

Crump was competent to stand trial. Immediately following the competency hearing, Crump again

harmed himself and was transported to the hospital. Approximately two weeks later, Crump pled

guilty to four of the five counts in the indictment with an agreement that the Government would

move to dismiss Count Two at sentencing.

On January 21, 2022, the district court held a sentencing hearing. Crump called his mother

as a witness in mitigation of his sentence. Ms. Crump recalled her son’s history of pediatric

seizures and self-harm and described how his mental health conditions had affected his

development. This testimony generally aligned with the Presentence Report, which detailed at

least seven recent incidents of self-harm or attempted self-harm and listed Crump’s reported

mental health diagnoses. Also before the court was Crump’s criminal history score of 26 points,

placing him in Criminal History Category VI.

The court calculated Crump’s guideline range. On Count Four, Crump faced a minimum

consecutive term of 84 months. On Counts One and Three, the relevant guideline range was 130

to 162 months. On Count Five, the relevant guideline range was 120 months because of a 10-year

statutory maximum. Crump asked for a sentence “at or below the applicable guideline range,”

while the Government requested the court vary upward to the statutory maximum of 240 months.

-2- No. 22-5073, United States v. Crump

Ultimately, the district court sentenced Crump to a total of 234 months’ imprisonment, consisting

of concurrent 150-month terms on Counts One and Three, a concurrent 120-month term on Count

Five, and the required consecutive 84-month term on Count Four.

The court cited the following facts in explaining its sentence: (1) the court’s belief that

Crump posed a high risk of recidivism; (2) Crump’s rehabilitative needs related to his mental

health conditions; and (3) Crump’s 26 criminal history points, which placed him in the highest

criminal history category. The court noted that “some of the criminal history . . . is related to

mental health issues,” although it was “concerned that those issues will continue going forward.”

It reasoned a within-Guidelines term of 150 months and a concurrent term of 120 months, in

addition to the required consecutive 84-month term, was sufficient but not greater than necessary

to meet the purposes of 18 U.S.C. § 3553.

II. ANALYSIS

Crump appeals his sentence, arguing it is substantively unreasonable because the court

failed to adequately weigh his mental health conditions.1 A challenge to the substantive

reasonableness of a criminal sentence by a defendant is essentially an argument that the sentence

is too long. United States v. Rayyan, 885 F.3d 436, 442 (6th Cir. 2018). The substantive

reasonableness inquiry determines if the length of a sentence conforms with the sentencing goals

set forth in 18 U.S.C. § 3553(a) and asks whether the district judge “‘abused his discretion in

determining that the § 3553(a) factors supported’ the sentence imposed.” Holguin-Hernandez

v. United States, 140 S. Ct. 762, 766 (2020) (quoting Gall v. United States, 552 U.S. 38, 56 (2007)).

1 Crump also mentions procedural reasonableness in his brief; however, he does not provide any arguments that his sentence was procedurally unreasonable. And he admits, “[t]he argument in the present case tends to be one of substance, more than procedure, insofar as the sentencing court failed to properly weigh and consider the factors set forth in 18 U.S.C. § 3553(a) . . . .” We agree and review Crump’s sentence only for substantive reasonableness.

-3- No. 22-5073, United States v. Crump

One way to gauge the substantive reasonableness of a sentence is to ask whether “the court placed

too much weight on some of the § 3553(a) factors and too little on others” in reaching its

sentencing decision. United States v. Parrish, 915 F.3d 1043, 1047 (6th Cir. 2019) (quoting

Rayyan, 885 F.3d at 442). If the court failed to give “reasonable weight to each relevant factor,”

the sentence that results is substantively unreasonable. United States v. Boucher, 937 F.3d 702,

707 (6th Cir. 2019) (emphasis omitted). Moreover, a sentence within the applicable guideline

range is afforded a rebuttable presumption of reasonableness. Id.; United States v. Brogdon, 503

F.3d 555, 559 (6th Cir. 2007).

Applying this framework, we cannot say that Crump’s within-Guidelines sentence is

substantively unreasonable. The district court considered Crump’s serious mental health

conditions and determined that its imposed sentence best took those conditions and other factors,

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Related

Gall v. United States
552 U.S. 38 (Supreme Court, 2007)
United States v. John Tolbert, Jr.
459 F. App'x 541 (Sixth Circuit, 2012)
United States v. Brogdon
503 F.3d 555 (Sixth Circuit, 2007)
United States v. Khalil Abu Rayyan
885 F.3d 436 (Sixth Circuit, 2018)
United States v. Richard Parrish
915 F.3d 1043 (Sixth Circuit, 2019)
United States v. Rene Boucher
937 F.3d 702 (Sixth Circuit, 2019)
United States v. Michael Owen
940 F.3d 308 (Sixth Circuit, 2019)
Holguin-Hernandez v. United States
589 U.S. 169 (Supreme Court, 2020)
United States v. Norman West
962 F.3d 183 (Sixth Circuit, 2020)

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