United States v. Richode Meredith-Hill

CourtCourt of Appeals for the Sixth Circuit
DecidedFebruary 9, 2024
Docket23-3409
StatusUnpublished

This text of United States v. Richode Meredith-Hill (United States v. Richode Meredith-Hill) 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. Richode Meredith-Hill, (6th Cir. 2024).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 24a0061n.06

No. 23-3409 FILED UNITED STATES COURT OF APPEALS Feb 09, 2024 FOR THE SIXTH CIRCUIT KELLY L. STEPHENS, Clerk

) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE NORTHERN ) DISTRICT OF OHIO RICHODE MEREDITH-HILL, ) Defendant-Appellant. ) OPINION )

Before: SUTTON, Chief Judge; CLAY and BLOOMEKATZ, Circuit Judges.

CLAY, Circuit Judge. Following the district court’s vacatur of Defendant Richode

Meredith-Hill’s original sentence, Meredith-Hill appeals the judgment of the district court upon

resentencing, arguing that his new sentence is procedurally unreasonable. For the reasons set forth

below, we AFFIRM the judgment of the district court.

I. BACKGROUND A. Meredith-Hill’s Underlying Offense

Meredith-Hill was part of a large, organized group called the “Rack Gang,” which

perpetrated a series of credit union robberies throughout 2017. On April 3, 2017, Meredith-Hill

participated in two armed robberies at two different credit unions. First, Meredith-Hill and three

others tried to rob the Buckeye State Credit Union in Shaker Heights, Ohio, but the group was

unsuccessful in obtaining any money. Second, the four men robbed over $10,000 from the

Cardinal Community Credit Union in Willoughby, Ohio. The Cardinal Community robbery

culminated in a perilous high-speed chase, during which the group successfully fled and evaded No. 23-3409, United States v. Meredith-Hill

the local police in a stolen vehicle. Both robberies were committed with firearms and involved

serious threats of physical violence.

During the FBI’s subsequent investigation, Meredith-Hill admitted his involvement and

claimed that he drove the getaway vehicle for both robberies. In contrast, one of the other

participants in the robberies, Lashawn Davis, told the police that Meredith-Hill played a more

active role by entering the credit unions with a firearm. The investigation determined that

Meredith-Hill likely entered and robbed the Buckeye State Credit Union because his DNA

matched the DNA found on the black gloves used during the crime. As for the Cardinal

Community Credit Union robbery, the investigation found it likely that Meredith-Hill did serve as

the getaway driver and fled at recklessly high speeds from police. Based on the conflicting

evidence and confessions, the investigation was ultimately inconclusive as to Meredith-Hill’s

exact role in the two robberies. When Meredith-Hill was subsequently arrested, he recanted his

prior confession.

Following a jury trial in October 2019, the jury found Meredith-Hill guilty of aiding and

abetting the following counts: (1) attempted interference with commerce by means of robbery in

violation of 18 U.S.C. § 1951 [Buckeye Credit Union]; (2) carrying a firearm in relation to a crime

of violence in violation of 18 U.S.C. § 924(c) [Buckeye Credit Union]; (3) interference with

commerce by means of robbery in violation of 18 U.S.C. § 1951 [Cardinal Credit Union]; and (4)

carrying a firearm in relation to a crime of violence in violation of 18 U.S.C. § 924(c) [Cardinal

Credit Union].1 To summarize, Meredith-Hill was convicted of two counts related to the robberies,

and two accompanying counts related to the firearms brandished during the robberies.

1 The jury acquitted Meredith-Hill of a fifth count related to the alleged attempted robbery of the Eaton Family Credit Union.

2 No. 23-3409, United States v. Meredith-Hill

B. Meredith-Hill’s Original Sentence

During Meredith-Hill’s initial sentencing on January 10, 2020, the district court adopted

the calculation within the presentence report, which set Meredith-Hill’s total offense level at 28

and his criminal history category at II, corresponding to a Guidelines range of 87 to 108 months’

imprisonment for the robbery and attempted robbery counts (Counts 1 and 3). The court also

recognized that Counts 2 and 4 carried mandatory seven-year minimum sentences to be served

consecutively. Therefore, assuming the court chose the mandatory minimum, Meredith-Hill’s

aggregate advisory range was 255 to 276 months’ imprisonment.

Following its thorough consideration of the factors delineated in 18 U.S.C. § 3553(a) and

arguments from both sides, the district court imposed an 87-month sentence for Counts 1 and 3 to

run concurrently. Then, with respect to the § 924(c) charges in Counts 2 and 4, the district

court imposed the minimum seven-year sentence for each to be served consecutively, totaling

168 months of imprisonment. In the aggregate, the district court initially imposed a 255-month

sentence. Upon appeal, this Court affirmed Meredith-Hill’s conviction and sentence. See United

States v. Meredith-Hill, No. 20-3083, 2021 WL 3079695, at *9 (6th Cir. July 21, 2021).

C. Meredith-Hill’s Resentencing

Following the Supreme Court’s holding that attempted Hobbs Act robbery cannot

constitute a crime of violence for purposes of § 924(c), see United States v. Taylor, 596 U.S. 845,

860 (2022), Meredith-Hill filed a 28 U.S.C. § 2255 motion to vacate his conviction on Count 2.

Based on the newly disqualified predicate crime in Count 1—attempted Hobbs Act robbery—the

corresponding § 924(c) firearm charge in Count 2 could no longer stand. The government filed a

response in agreement, and the district court accordingly vacated Meredith-Hill’s conviction on

3 No. 23-3409, United States v. Meredith-Hill

Count 2 and scheduled a de novo resentencing hearing. Count 4—with the predicate offense of

completed Hobbs Act robbery—was not affected by the holding in Taylor.

Upon resentencing, although the seven-year minimum sentence under Count 2 was

vacated, the presentence report calculated a higher total offense level of 31 for Counts 1 and 3.

This change stemmed from a corresponding five-level increase under U.S.S.G. § 2B3.1(b)(2)(C)

to Count 1 for brandishing a firearm during the attempted robbery of Buckeye State Credit Union.2

Combined with his unchanged criminal history category of II, the advisory Guidelines range for

Counts 1 and 3 became 121 to 151 months’ imprisonment, and Count 4 still carried a seven-year

mandatory minimum to be imposed consecutively. Therefore, adding in the seven-year mandatory

minimum, the presentence report recommended a total range of 205 to 235 months’ imprisonment.

During the resentencing hearing, Meredith-Hill did not object to the presentence report and agreed

that its calculation was accurate.

After explaining the applicable Guidelines range, the district court carefully considered

each of the factors in 18 U.S.C. § 3553(a). First, the court recognized that the nature and

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