United States v. Patricia Lynn Puckett
Docket: 93-5705
Court: Court of Appeals for the Fourth Circuit; April 14, 1994; Federal Appellate Court
Patricia Lynn Puckett was convicted of conspiracy to possess controlled substances and sentenced to fifty-eight months in prison. The government appealed the sentence, arguing that the district court had improperly determined Puckett had accepted responsibility and was only responsible for a portion of the drugs involved. The Fourth Circuit vacated the initial sentence and remanded for resentencing within the recommended range of 87-108 months. On remand, the district court imposed a sentence of 87 months. Puckett appealed again, claiming error in the district court’s failure to determine when she entered the conspiracy and the amount of drugs she could reasonably foresee. The appellate court affirmed the 87-month sentence, stating that Puckett had forfeited her right to challenge the guideline calculations as she did not object to the drug amounts in the presentence report during her first sentencing. The court emphasized that issues forfeited in the district court cannot typically be relitigated unless extraordinary circumstances exist, which were not present in this case. The appellate court also dismissed concerns regarding the disparity between Puckett’s sentence and that of her co-defendant, Ruth Casey, noting that Casey's plea agreement and sentence were not under review in this appeal. The court reiterated that plea agreements should not distort the application of sentencing guidelines. The judgment of the district court was ultimately affirmed.