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United States v. Steven Miller
Citation: Not availableDocket: 01-1861
Court: Court of Appeals for the Eighth Circuit; July 8, 2002; Federal Appellate Court
Original Court Document: View Document
Steven Tyrone Miller and Jamo Jenkins appeal their sentences related to a drug conspiracy involving cocaine, marijuana, and PCP. Indicted alongside 52 others in June 1998 on 67 counts, Miller pleaded guilty to conspiracy under a plea agreement that included cooperation with the government, resulting in an initial sentence of 420 months, later reduced to 204 months following a Rule 35 hearing. Jenkins was convicted by jury of conspiracy and possession with intent to distribute, receiving a 330-month sentence. However, the Eighth Circuit remanded for resentencing, concluding that Jenkins should be presumed guilty of the least serious offense, marijuana. On remand, the district court set maximum sentences of 60 months for each count while reaffirming Jenkins's involvement in cocaine distribution, leading to consecutive sentences due to the higher sentencing range. Miller's appeal focuses on an alleged oral agreement during plea negotiations for a greater sentence reduction than stipulated in the written agreement, which the government denies. The court reviewed the interpretation of the plea agreement de novo, affirming that the written document was clear and comprehensive, reflecting all terms between the parties. The district court determined that Miller's understanding of his obligations and the government's recommendations were accurately captured in the plea agreement, noting concerns regarding his cooperation level. The court found no error in the district court’s rulings. The district court expressed a strong inclination to reduce Miller’s sentence to 20 years due to his lack of cooperation and questionable credibility during testimony. However, the sentence imposed at the Rule 35 hearing is affirmed. In Jenkins’s first appeal, the court required the district court to sentence Jenkins within the statutory maximum for marijuana distribution, aligning with the Supreme Court's ruling in Apprendi v. New Jersey, which mandates that any fact increasing a penalty beyond the statutory maximum must be proven to a jury. On remand, Jenkins was sentenced to the maximum of 60 months for each count, to run consecutively. Jenkins argued that the district court erred by considering his involvement in cocaine distribution as relevant conduct, which would have otherwise limited his sentence to a maximum of 16 months under the guidelines for marijuana offenses. The court disagreed, clarifying that Apprendi applies only when the defendant is sentenced beyond the statutory maximum. The district court has the discretion to determine the types and amounts of drugs involved, provided the sentence does not exceed that for the marijuana offense. The ruling in Edwards v. United States supports this, indicating that Nattier is not applicable when jury ambiguity only affects sentencing guideline application. The district court correctly utilized the guidelines based on its findings regarding Jenkins's cocaine distribution involvement and appropriately ordered consecutive sentences, as mandated by U.S.S.G. 5G1.2(d). The court affirmed that Jenkins's convictions were grouped for determining his base offense level, consistent with the guidelines. Ultimately, the judgments are affirmed.