Narrative Opinion Summary
This case involves appeals by two defendants who were convicted of conspiracy to distribute cocaine base under 21 U.S.C. §§ 841(a)(1) and 846. The convictions resulted from an investigation into crack cocaine distribution, during which undercover operations revealed the defendants' involvement in drug transactions. The primary issue on appeal was the sufficiency of evidence supporting the conspiracy convictions, particularly focusing on the attribution of drug quantities for sentencing purposes. One defendant, Rue, challenged the district court's determination attributing a half-kilo of cocaine to her, arguing insufficient evidence of her intent and ability to deliver that amount. The district court, however, upheld the attribution based on her recorded conversations and past transactions, finding that she intended to deliver the drugs. Additionally, Rue's failure to object during sentencing waived her right to appeal on those grounds, unless a manifest injustice could be shown. The court also examined whether the amended Application Note 12 of the sentencing guidelines should apply retroactively, but concluded that it was unnecessary to resolve this issue, as Rue could not demonstrate manifest injustice. Ultimately, the court affirmed the convictions and sentences, finding the evidence sufficient to support the jury's verdicts.
Legal Issues Addressed
Application of Amended Sentencing Guidelinessubscribe to see similar legal issues
Application: The court considered whether the amended Application Note 12 should apply retroactively but determined that regardless of its application, Rue failed to show manifest injustice in her sentencing.
Reasoning: Both the government and Rue contend that the court should apply the amended Application Note 12, effective 1995, instead of the version in place during her sentencing.
Conspiracy to Distribute Cocaine Base under 21 U.S.C. §§ 841(a)(1) and 846subscribe to see similar legal issues
Application: The court found sufficient evidence to uphold the convictions of both defendants for conspiracy to distribute cocaine base, based on recorded conversations and drug transactions with undercover agents.
Reasoning: The Court affirmed the convictions and Rue's sentence.
Sentencing Attribution for Drug Quantity under U.S.S.G. § 2D1.1subscribe to see similar legal issues
Application: The court attributed the full half-kilo of cocaine base to Rue based on her intent to deliver, as evidenced by her recorded conversations and past transactions, despite her challenge to the sufficiency of evidence for such attribution.
Reasoning: Rue contested the sentencing attribution of a half-kilo of cocaine to her, arguing she never intended to deliver it and could not procure that amount based on her previous smaller transactions.
Waiver of Objections to Sentencingsubscribe to see similar legal issues
Application: Rue's failure to object during the sentencing hearing to the court's determination of drug quantity waived her right to challenge this on appeal, unless manifest injustice would result.
Reasoning: Objections to a sentence will be waived for appeal if a party remains silent or fails to specify grounds for objection, unless not addressing them results in manifest injustice.