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United States v. Todd A. Miller
Citations: 458 F.3d 603; 2006 U.S. App. LEXIS 20736; 2006 WL 2337633Docket: 05-4295
Court: Court of Appeals for the Seventh Circuit; August 14, 2006; Federal Appellate Court
Todd Miller pleaded guilty to two counts: possession of a firearm as a felon and possession of cocaine with intent to distribute, resulting in a 188-month prison sentence. He contested the government's choice not to file a substantial assistance motion after his plea, where he had agreed to cooperate with law enforcement. The government opted not to file this motion, citing concerns over Miller's lack of candor regarding the source of the cocaine found on him. In addressing Miller's appeal, the court highlighted the broad discretion granted to the Attorney General and U.S. Attorneys in enforcing criminal laws, which includes decisions related to substantial assistance motions. This discretion is generally presumed to be exercised properly unless there is clear evidence of unconstitutional motives, such as discrimination based on race or religion, or if the decision lacks any rational basis related to legitimate governmental interests. The court found no evidence of unconstitutional motives in Miller's case and upheld the government's decision as rationally based. Miller compares his case to Wilson, where the court found the government's actions lacked a rational basis. In Wilson, the government's aim to prevent a civil suit was deemed irrational relative to the purposes of 5K1.1 and Rule 35(b). In contrast, the government here declined to file a motion for Miller due to his perceived lack of honesty about his cocaine source, a decision deemed a reasonable "judgment call" within its discretion. Miller argues this rationale is pretextual, citing an officer's testimony indicating his reliability and truthfulness, as he provided significant information leading to marijuana charges against another individual. However, the government maintains that his cooperation regarding the cocaine source was insufficient, justifying its discretion not to file the motion. Miller's claims hold little weight as the government properly exercised its discretion and provided a rational basis for its decision. Additionally, Miller contends that the government did not adequately "consider" filing the motion as per the plea agreement and seeks a district court hearing to investigate the U.S. Attorney's Office's internal deliberations. The court denies this request, affirming that as long as the government offers a rational basis for its decision, further inquiry into its internal discussions is unnecessary. Consequently, the judgment of the district court is affirmed.