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United States v. Joshua D. Stapleton
Citations: 268 F.3d 597; 2001 U.S. App. LEXIS 20317; 2001 WL 1041870Docket: 01-1480
Court: Court of Appeals for the Eighth Circuit; September 12, 2001; Federal Appellate Court
Joshua Stapleton appealed his sentence for unlawful possession of a firearm by a convicted felon, arguing that the district court improperly relied on a presentence report (PSR) that included disputed factual findings regarding his criminal history. Stapleton objected to the inclusion of two municipal convictions and a 1992 juvenile adjudication in his criminal history score, asserting that he did not plead guilty to the municipal charges and that the juvenile conviction did not fall within the relevant time frame for consideration under sentencing guidelines. The appellate court determined that a specific objection to the PSR obligates the district court to resolve the factual dispute based on evidence, not merely adopt the PSR’s findings. The sentencing judge acknowledged Stapleton's objections but failed to conduct a thorough inquiry or allow for cross-examination of the probation officer who prepared the PSR. The court highlighted that the government did not present evidence to substantiate its claims regarding Stapleton's prior convictions, relying solely on the probation officer's statements. The appeals court concluded that the district court erred by not requiring the government to meet its burden of proof in addressing the contested facts, emphasizing the necessity of some form of investigation or verification when a defendant challenges the PSR's accuracy. The government argues that Stapleton's plea agreement bars him from challenging his sentence. However, the court interprets the agreement differently, noting that while Stapleton waived his right to appeal the constitutionality of the Sentencing Guidelines, he is contesting the trial court's failure to hold a hearing on disputed evidence. The plea agreement allows the parties to address any sentencing issues not covered in the agreement, which the court concludes includes the sufficiency of the evidence regarding Stapleton's prior convictions. As a result, the court reverses Stapleton's sentence and remands the case for the district court to make a factual determination and conduct resentencing. The record will be reopened for both parties to present evidence on the disputed convictions.