United States v. Lawler

818 F.3d 281, 2016 U.S. App. LEXIS 4832, 2016 WL 1055857
CourtCourt of Appeals for the Seventh Circuit
DecidedMarch 16, 2016
DocketNo. 15-1496
StatusPublished
Cited by9 cases

This text of 818 F.3d 281 (United States v. Lawler) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh 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. Lawler, 818 F.3d 281, 2016 U.S. App. LEXIS 4832, 2016 WL 1055857 (7th Cir. 2016).

Opinion

WILLIAMS, Circuit Judge.

Jean Lawler pleaded guilty to distributing heroin and conspiring to possess heroin with the intent to distribute it. The district court found, by a preponderance of the evidence, that Lawler sold the heroin that killed one of the conspiracy’s customers. On that basis; in determining Lawler’s Guidelines-recommended sentence, the court followed U.S.S.G. § 2D1.1(a)(2), which applies if “the offense of conviction establishes that death ... resulted from the use of the [heroin].” That was erroneous. Lawler’s “offense of conviction” — distributing heroin and conspiring to possess heroin with the' intent to distribute it— does not “establish” that a death resulted. Therefore, we vacate Lawler’s sentence and remand.

I. BACKGROUND

The facts of this case were fully described in United States v. Walker, 721 F.3d 828, 831-33 (7th Cir.2013). Relevant here, Lawler was charged along with thirty other defendants in a single-count indictment that described a large-scale heroin-distribution conspiracy that led to the overdose deaths of five people. “Lawler was a low-level member of the conspiracy” who “purchased relatively small quantities of heroin ... to resell to .others and for personal use.” Id. at 831.

Lawler pleaded guilty to distributing heroin and conspiring to possess heroin with the intent to distribute it, in violation of 18 U.S.C. § 2 and 21 U.S.C. §§ 841(a)(1), (b)(1)(A), and 846. The applicable statutory sentencing range is 10 years to life. 21 U.S.C. § 841(b)(1)(A). The statutory minimum is increased to 20 years if death results from the.use of the heroin. Id. The Sentencing Guidelines also recommend a longer sentence when death results, increasing the base offense level if “the offense of conviction establishes” that death resulted. U.S.S.G. § 2D1.1(a)(2).

Lawler’s plea agreement stated that the government would argue that Lawler was subject to both the 20-year statutory minimum and the increased base offense level because she sold the heroin that led to a particular death — that of Jeffrey Topezew-ski. , Lawler disagreed and reserved her right to contest those issues.. At sentencing, the district court found, by a preponderance of the evidence, that Lawler sold the heroin that killed Topezewski, so it applied the 20-year statutory minimum. We affirmed because the court’s finding— applying a preponderance-of-the-evidence standard — was supported by sufficient evidence. See Walker, 721 F.3d at 841-42. The Supreme Court vacated Lawler’s sentence in light of Alleyne v. United States, — U.S. -, 133 S.Ct. 2151, 186 L.Ed.2d 314 (2013), which held that any fact that increases the statutory minimum sentence must be found beyond a reasonable doubt. Lawler v. United States, — U.S. -, 134 S.Ct. 2287, 189 L.Ed.2d 169 (2014) (mem.).

On remand, the government conceded that the 20-year statutory minimum did not apply because’ it had not been proven .beyond a reasonable doubt that Lawler sold the heroin that killed Topezewski. But the government maintained that Lawler’s base offense level should be 38, under U.S.S.G. § 2D1.1(a)(2). The district court agreed. That decision had a significant consequence: Lawler’s Guidelines-recommended range soared from 15-21 months to 168-210 months. In part due to her substantial assistance to the government, [283]*283see 18 U.S.C. § 3553(e); U.S.S.G. § 5K1.1, Lawler was sentenced to 98 months in prison.

II. ANALYSIS

Lawler’s argument is simple: she was not convicted of causing Topczewski’s death, so § 2Dl.l(a)(2) — which by its text applies -only when the “offense of conviction establishes” that death resulted — does not apply. We review the district court’s interpretation of the Guidelines de novo. United States v. Woolsey, 535 F.3d 540, 549 (7th Cir.2008).

The first part of Lawler’s argument — that she was not convicted of causing Topczewski’s death — is certainly correct. It is true that' Lawler’s indictment referenced Topczewski’s death. But that is also true of thirty other defendants who were charged in a single count describing a large-scale conspiracy that resulted in five deaths. We already held that the combination of this indictment and a plea of guilty (to distributing heroin and conspiring to possess heroin with the intent to distribute it) did not prove that any particular defendant was responsible for any particular death. Walker, 721 F.3d at 836-38; see also id. at 841-42 (discussing the evidence connecting Lawler to Top-czewski’s death, rather than drawing conclusions from the indictment and guilty plea). The government conceded that it did not prove beyond a reasonable doubt that Lawler caused Topczewski’s death, and Lawler explicitly disputed that fact in her plea agreement.1 So the death is not part of her conviction. See Burrage v. United States, — U.S. -, 134 S.Ct. 881, 887, 187 L.Ed.2d 715 (2014) (“Because the ‘death results’ enhancement increased the minimum and maximum sentences to which Burrage was exposed, it is an element that must be submitted to the jury and found beyond a reasonable doubt.”).

The next question is whether § 2D1.1(a)(2) applies when death is not inherent in the conviction but the district court finds, by a preponderance of the evidence, that death resulted. Lawler says no, relying on the provision’s text. Importantly, numerous Guidelines provisions -turn on the actual consequences of the defendant’s “offense.”2 In contrast, § 2D1.1(a)(2) looks only to what is “estab-[284]*284lishe[d]” by the defendant’s “offense of conviction,”3

The Guidelines make clear that “offense of conviction” and “offense” have different meanings. Specifically, § 1B1.1 n. 1 defines “offense” to mean “offense of conviction” plus' “all relevant' conduct.” And “relevant conduct” means “all acts and omissions ... that occurred during the commission of the offense of conviction,'in preparation for that offense, or in the course of attempting to avoid detection or responsibility for that offense[.]” § IB 1.3(a). Together these provisions show that:' (1) “offense of conviction” does not include “relevant conduct”; and ■ (2) “offense of conviction” is narrower than “offense.” See United States v. Rebmann, 321 F.3d 540, 543-44 (6th Cir.2003) (reaching this conclusion after textual analysis); United States v. Pressler, 256 F.3d 144, 157 n. 7 (3d Cir.2001) (same); see also United States v. Blackwell, 323 F.3d 1256, 1260 (10th Cir.2003) (same, in the context of a different Guideline provision).

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Bluebook (online)
818 F.3d 281, 2016 U.S. App. LEXIS 4832, 2016 WL 1055857, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-lawler-ca7-2016.