United States v. Leviner

31 F. Supp. 2d 23, 1998 U.S. Dist. LEXIS 20323, 1998 WL 909980
CourtDistrict Court, D. Massachusetts
DecidedDecember 22, 1998
DocketCRIM. 97-10260-NG
StatusPublished
Cited by24 cases

This text of 31 F. Supp. 2d 23 (United States v. Leviner) 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. Leviner, 31 F. Supp. 2d 23, 1998 U.S. Dist. LEXIS 20323, 1998 WL 909980 (D. Mass. 1998).

Opinion

SECOND AMENDED ORDER RE: SENTENCING

GERTNER, District Judge.

TABLE OF CONTENTS SECOND AMENDED ORDER RE: SENTENCING
I. FACTS....................................................................24
A. Offense................................................................24
B. Offender...............................................................25
II. GUIDELINE CALCULATIONS.............................................25
III. SHOULD A FELONY CONVICTION RECEIVED AFTER THE INSTANT OFFENSE BE COUNTED IN CONNECTION WITH SENTENCING FOR FELON IN POSSESSION CHARGE?.................................26
A. 18 U.S.C. Section 922(g)(1)..............................................-.26
B. Structure of the Guidelines...............................................27
C. Language of the Guidelines..............................................28
IV. WHETHER LEVINER’S CRIMINAL HISTORY OVERSTATES HIS CULPABILITY ..............................................................31
A. Purpose of the Criminal History System...................................32
B. The Significance of Measuring Criminal History Points by the Length of Sentence the Prior Conviction Received....................................32
*24 1. The criminal history score does not accurately reflect the relatively minor nature of Leviner’s record.......................................32
2. The criminal history score does not accurately reflect the non-violent nature of Leviner’s record............................................32
3. The criminal history score mirrors disparities in state sentencing, and in particular, racial disparities.........................................33
C. The Defendant’s Overall Record Relative to Other Offender Information.......33
THE RELATIONSHIP BETWEEN THIS FEDERAL SENTENCE AND A 34 V. PENDING STATE SENTENCE
34 VI. SENTENCE........................

The sentencing of Alexander Leviner (hereinafter “Leviner”) raises two major issues:

First, should Leviner’s sentence for Felon in Possession of a Firearm be based on a conviction that occurred after the possession itself, as the Government argues. I conclude that it should not. If the United States Sentencing Commission Guideline (“the Guideline(s)”) commentary suggests such an interpretation- — and in my judgment, it does not — then the commentary is necessarily trumped by the Felon in Possession statute itself, 18 U.S.C. § 922(g), and the language of the Guidelines, not to mention logic and fun-:-damental fairness. See infra Section III.

Second, should this Court depart from the Guideline range on the grounds that Levi-ner’s record — overwhelmingly motor vehicle violations and minor drug possession offenses — overstates his culpability and the likelihood of his recidivism? I conclude that Leviner’s record does so, and thus I will depart downward. See infra Section IV. A system for evaluating criminal history, like the Federal Guidelines system, which assigns points for past convictions solely according to the length of sentence the defendant received, necessarily replicates disparities in state sentencing. Furthermore, even more profound concerns are raised where, as here, the defendant is African American, the convictions were largely motor vehicle offenses, for which the defendant was imprisoned. The scholarly and popular literature strongly suggests that there is racial disparity in the rates at which African Americans are stopped and prosecuted for traffic offenses. That literature, together with the specific facts about Leviner’s record and background, compel me to depart from the Guideline range.

Alexander Leviner pled guilty to the charge of Felon in Possession of a Firearm in violation of 18 U.S.C. § 922(g)(1). The indictment charges Leviner with possessing a 9 mm Smith and Wesson, semiautomatic handgun, together with fourteen rounds of ammunition. Leviner, the indictment further charges, had previously been convicted of a crime punishable by a term of imprisonment exceeding one year.

The data on which this sentencing decision is based are as follows: A two-day hearing that was held on Defendant’s Motion To Suppress, which described the circumstances of Leviner’s arrest; (see Memorandum and' Order dated June 29, 1998); the plea colloquy; and a two-day sentencing hearing.

I. FACTS 1

A. Offense

The car in which Leviner was a passenger was observed by police officers as traveling at a high rate of speed, without headlights, from an area in which shots had reportedly been fired. The officers followed the car and stopped it. The officers reported that the occupants of the car (the driver — Denise Cummings, the front seat passenger — Derrick Johnson, and Leviner, who was seated in the rear) were cooperative, that they produced the requested documentation (license and registration for the driver, identification for the passengers), answered all questions posed to them, and even agreed to be searched. But for the fact that Cumming’s registration did not match the car she was driving, the officers were prepared to allow *25 them to leave. As a result of the registration disparity, Leviner and the others were asked to step out of the car. At some point the officers found a holster on Leviner, and he fled. The officers apprehended him almost immediately and found the gun in question on the car floor near where Leviner had been sitting.

The Government has also represented that tests indicate that shots had been fired from Leviner’s gun and a shell casing was found on the car floor. There was, however, no indication that the gun was fired at anyone in particular, or even that anyone was threatened by its use. The Government does not even make such an accusation.

The offense is unquestionably a serious one. The Assistant United States Attorney quite appropriately points out that this was not the mere possession of the firearm, but its firing. While the gun was not used to threaten anyone, it was nevertheless used,. 2

B.Offender

Leviner has had a consistent employment record. He is a trained asbestos removal worker, regularly employed over the past ten years.

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Bluebook (online)
31 F. Supp. 2d 23, 1998 U.S. Dist. LEXIS 20323, 1998 WL 909980, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-leviner-mad-1998.