United States v. Ronnie Edward Duke

CourtCourt of Appeals for the Sixth Circuit
DecidedSeptember 30, 2025
Docket25-1213
StatusUnpublished

This text of United States v. Ronnie Edward Duke (United States v. Ronnie Edward Duke) 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. Ronnie Edward Duke, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0442n.06

Case No. 25-1213

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Sep 30, 2025 KELLY L. STEPHENS, Clerk ) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE v. ) UNITED STATES DISTRICT ) COURT FOR THE EASTERN RONNIE DUKE, ) DISTRICT OF MICHIGAN Defendant-Appellant. ) _______________________________________ ) OPINION

Before: SUTTON, Chief Judge; BATCHELDER and LARSEN, Circuit Judges.

ALICE M. BATCHELDER, Circuit Judge. Beginning in 2012, Ronnie Duke had a

series of run-ins with the law, which included conspiracy to commit wire fraud, failure to

surrender, assault of a federal official, and attempting to escape detention. In 2023, after the district

court had sentenced Duke for each of these offenses, the Sentencing Commission promulgated

Amendment 821. Because this amendment impacted Duke’s criminal history score in his assault

conviction, Duke filed a motion to reduce his sentence for that conviction. The district court denied

the motion, and Duke now appeals. We affirm.

I.

In 2012, Duke was convicted and sentenced to 156 months’ imprisonment for conspiracy

to commit wire fraud (Case One). United States v. Duke, 870 F.3d 397, 399 (6th Cir. 2017).

However, Duke failed to self-report to prison for this sentence, leading to an arrest warrant and a

new federal indictment charging him with failure to surrender for a sentence, in violation of

18 U.S.C. § 3146(a)(2) (Case Two). Id. Duke was then arrested for his failure to surrender, and No. 25-1213, United States v. Duke

at his arraignment hearing, Duke violently attacked the government’s counsel after counsel

opposed Duke’s request to be transferred to a different prison facility. Id. at 399-400. Duke hurled

expletives at counsel, struck her in the face numerous times, and repeatedly “smashed” her head

into the table. Id. at 400. A federal grand jury later indicted Duke on one count of assaulting a

federal officer, in violation of 18 U.S.C. § 111(a)(1), (b) (Case Three). Id.

While detained for the failure-to-surrender and assault charges, Duke attempted to escape

from the detention facility. This resulted in the government’s obtaining a superseding indictment

in Case Two that added an attempted-escape charge. This meant that Case Two included two

counts: failure to surrender and attempted escape. Duke pleaded guilty to the assault of a federal

officer in Case Three. Duke, 870 F.3d at 400. At the same hearing, Duke also pleaded guilty to

both of the charges in Case Two.

The Presentence Investigation Report (“PSR”) for the assault charge calculated that Duke

had six criminal-history points: three points from Case One, one point from Case Two, and two

points for committing the assault while under a criminal-justice sentence for Case One. This score

placed Duke in Criminal History Category III.

At sentencing for the assault charge, Duke objected to the PSR’s application of the

criminal-history point for Case Two. The district court did not rule on the objection at the time

because Duke remained at Criminal History Category III, even without that point. The district

court sentenced Duke to 97 months’ imprisonment for the assault charge. At the subsequent

sentencing hearing for Case Two, the district court sentenced Duke to 18 months’ imprisonment

for the failure-to-surrender and attempted-escape charges. Duke appealed his 97-month sentence

from Case Three, and this Court affirmed. United States v. Duke, 870 F.3d at 406. Duke later

2 No. 25-1213, United States v. Duke

filed a 28 U.S.C. § 2255 motion challenging his conviction in Case Three, but it was denied as

untimely.

Since then, the Sentencing Commission has retroactively amended the Guidelines. On

November 1, 2023, Part A of Amendment 821 took effect, reducing the number of criminal history

points assessed against a defendant based on prior convictions (“status points”). U.S.S.G.

§ 4A1.1(e) (2023). Because this retroactive change affected Duke’s sentence in Case Three, he

moved for a sentence reduction under 18 U.S.C. § 3582(c)(2), and renewed his prior objection to

the additional criminal-history point assessed from Case Two. Duke renewed this objection

because if the district court reduced his criminal score by one point—in addition to the loss of the

two status points from the retroactive change—he would drop to a Criminal History Category II.

The district court denied the motion, finding that Duke’s guilty plea from Case Two

counted as a “prior sentence,” according to the text of U.S.S.G. § 4A1.2(a)(1), and although the

attempted escape might have been relevant conduct to the assault, the failure to surrender was not.

This meant that the additional criminal history point was properly assessed, and Duke’s Criminal

History Category remained at III, making Duke ineligible for a sentence modification. Because

the district court held that Duke was ineligible for the sentence reduction, it did not consider

whether the 18 U.S.C. § 3553(a) factors weighed in favor of a reduction.

Duke appeals, arguing that the district court erred by finding that the failure-to-surrender

conviction was not relevant conduct to the assault, and hence, the criminal-history point applied.

II.

Generally, once the district court imposes a sentence, it may not be modified. However,

§ 3582(c)(2) provides an exception and allows modification when a defendant “has been sentenced

to a term of imprisonment based on a sentencing range that has subsequently been lowered by the

3 No. 25-1213, United States v. Duke

Sentencing Commission,” and the district court finds that a “reduction is consistent with” relevant

Guidelines policy statements. 18 U.S.C. § 3582(c)(2). This does not, however, require a full

resentencing. Rather, § 3582(c)(2) grants district courts the “power to ‘reduce’ an otherwise final

sentence in circumstances specified by the Commission.” Dillon v. United States, 560 U.S. 817,

825 (2010) (quoting § 3582(c)). Thus a § 3582(c)(2) sentencing modification proceeds in two

steps. Id. at 827. First, the district court must determine if the defendant is eligible for the

reduction under §1B1.10. Id. Second, if the district court finds that the defendant is eligible, it

must then “consider any applicable § 3553(a) factors and determine whether, in its discretion,” the

reduction is warranted. Id.

We review the denial of a sentence reduction for abuse of discretion. United States v.

Ruffin, 978 F.3d 1000, 1005 (6th Cir. 2020). “A district court abuses its discretion when it relies

on clearly erroneous findings of fact, or when it improperly applies the law or uses an erroneous

legal standard.” United States v.

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Related

Dillon v. United States
560 U.S. 817 (Supreme Court, 2010)
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United States v. Dennis Hodge
805 F.3d 675 (Sixth Circuit, 2015)
Marlon Scarber v. Carmen Palmer
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United States v. Ronnie Duke
870 F.3d 397 (Sixth Circuit, 2017)
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978 F.3d 996 (Seventh Circuit, 1992)

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