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United States v. McKeever

Citation: Not availableDocket: Criminal No. 2000-0250

Court: District Court, District of Columbia; June 26, 2017; Federal District Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, the defendant, representing himself, sought to have his 18-month federal sentence for a supervised release violation run concurrently with his 30-year state sentence, arguing that the consecutive sentence acted as a detainer, hindering his access to rehabilitative programs. The defendant cited United States v. Booker, yet failed to clearly establish a constitutional or advisory guideline basis for sentence reduction. The court interpreted the request as a motion under 18 U.S.C. § 3582(c), which permits sentence modification only under specific exceptions that were not applicable in this instance. The exceptions include motions by the Bureau of Prisons, statutory or rule-based permissions, or retroactive guideline changes. None were present here, leading the court to deny the request. The court emphasized its obligation to evaluate the substance of pro se motions rather than their labels, ultimately finding no grounds for relief and issuing an order denying the motion for sentence modification.

Legal Issues Addressed

Application of United States v. Booker

Application: The court determines that the principles in Booker do not support McKeever's request for a sentence reduction.

Reasoning: Defendant Mr. McKeever seeks a sentence reduction citing United States v. Booker, 543 U.S. 220 (2005), but it is unclear whether he argues on constitutional grounds or asserts that the Sentencing Guidelines are advisory. Regardless, the court finds Booker does not support his request for reduction.

Impact of Consecutive Sentences on Rehabilitation Access

Application: McKeever's argument that his consecutive sentence hinders rehabilitation access was previously considered and rejected during sentencing.

Reasoning: The government notes that McKeever raised this argument previously during his sentencing, which was rejected by the court in favor of an independent sentence for a supervised release violation.

Modification of Sentences under 18 U.S.C. § 3582(c)

Application: The court evaluates requests for sentence modification according to strict statutory exceptions, none of which applied to McKeever's case.

Reasoning: Ultimately, the court finds that McKeever's letter does not meet any of the necessary criteria for a sentence modification under § 3582(c) and therefore denies the request for a sentencing reduction.

Pro Se Litigant's Pleading Interpretation

Application: Courts are not bound by the labels pro se litigants use when requesting relief; instead, they assess the nature of the relief being sought.

Reasoning: The Court emphasized that it is not bound by how a pro se litigant labels their request and must assess the nature of the relief being sought.