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United States v. William Delmer Edwards, Jr.

Citations: 65 F.3d 430; 1995 U.S. App. LEXIS 26148; 1995 WL 550513Docket: 95-60167

Court: Court of Appeals for the Fifth Circuit; September 18, 1995; Federal Appellate Court

Narrative Opinion Summary

In this case, the appellant challenged the quantity of methamphetamine attributed to him following his guilty plea for possession with intent to distribute under 21 U.S.C. Sec. 841. The district court, after evaluating conflicting testimonies, attributed 452 grams to the defendant, impacting his sentencing. The defendant sought reductions in his offense level for minimal participation and under the safety valve provision of U.S.S.G. Sec. 5C1.2, both of which were denied. The court concluded that the defendant was significantly involved in the crime and had not provided truthful information to qualify for the safety valve. The appellate court reviewed the sentencing decisions, particularly the application of the Sentencing Guidelines and the district court's factual findings, for clear error. The court found no error and affirmed the sentence, noting that the defendant's involvement in weighing, hiding, and delivering drugs precluded a reduction for minimal participation. The appeal asserted that the district court failed to make adequate factual findings, but the appellate court upheld the district court's discretion and credibility assessments, ultimately affirming the 60-month sentence.

Legal Issues Addressed

Application of Sentencing Guidelines

Application: The appellate court reviewed the district court's application of the Sentencing Guidelines de novo, with factual findings reviewed for clear error.

Reasoning: The appellate court reviews the application of the Sentencing Guidelines de novo and factual findings for clear error...

Credibility and Evidence Evaluation

Application: The district court exercised discretion in evaluating evidence and credibility, crediting the DEA agent's testimony over the defendant's.

Reasoning: The district court, faced with conflicting evidence, chose to credit Agent Moffett's testimony, concluding that approximately 452 grams were involved in the transaction...

Denial of Reduction for Minimal Participation

Application: The court denied a reduction for minimal participation under U.S.S.G. Sec. 3B1.2, finding the defendant's involvement significant.

Reasoning: Edwards admitted to weighing, hiding drugs, accompanying co-conspirators on deliveries, and making independent sales, indicating a significant level of involvement.

Safety Valve Provision under U.S.S.G. Sec. 5C1.2

Application: The defendant's failure to provide truthful information about the drug quantity disqualified him from relief under the safety valve provision.

Reasoning: Although Edwards's challenge did not automatically exclude him from Sec. 5C1.2, his contradictory testimony and previous statements to law enforcement led the district court to determine he did not provide all relevant information truthfully.

Sentencing under 21 U.S.C. Sec. 841

Application: The court determined the amount of methamphetamine attributable to the defendant, affecting his sentence under the statute.

Reasoning: The district court chose to reduce the quantity attributed to Edwards to 452 grams, rejecting his lower estimate.