USA v. Tyler, No. 20-51011 (5th Cir. 2023)

Annotate this Case

This opinion or order relates to an opinion or order originally issued on September 12, 2023.

Download PDF
Case: 20-51011 Document: 00516942979 Page: 1 Date Filed: 10/24/2023 United States Court of Appeals for the Fifth Circuit United States Court of Appeals Fifth Circuit ____________ FILED October 24, 2023 No. 20-51011 ____________ Lyle W. Cayce Clerk United States of America, Plaintiff—Appellee, versus Steve Maurice Tyler, Defendant—Appellant. ______________________________ Appeal from the United States District Court for the Western District of Texas USDC No. 7:16-CR-128-5 ______________________________ Before Jones, Stewart, and Duncan, Circuit Judges. Per Curiam:* Appellant Steve Tyler pled guilty in 2016 to conspiracy to possess 280 grams or more of cocaine base with intent to distribute. The district court (Junell, J.) sentenced him to a statutory minimum 240-months of imprisonment. 21 U.S.C. § 841(b)(1)(A) (2010). We affirmed in part and _____________________ * Pursuant to 5th Circuit Rule 47.5, the court has determined that this opinion should not be published and is not precedent except under the limited circumstances set forth in 5th Circuit Rule 47.5.4. Case: 20-51011 Document: 00516942979 Page: 2 Date Filed: 10/24/2023 No. 20-51011 remanded in part. Having received the district court’s more complete explanation of its order, we now AFFIRM. Tyler moved for compassionate release pursuant to 18 U.S.C. § 3582(c)(1)(A). The government filed a response, and the district court (Counts, J.) denied the motion as follows: “After considering the applicable factors provided in 18 U.S.C. § 3553(a) and the applicable policy statements issued by the Sentencing Commission, the Court DENIES the Defendant’s Motions [sic] on its merits.” Tyler then filed a timely motion for reconsideration, which the court likewise denied. Tyler now appeals the denial of his motion for compassionate release. We review the district court’s decision for abuse of discretion. United States v. Cooper, 996 F.3d 283, 286 (5th Cir. 2021). Tyler argues that the district court erred in failing to assess whether his allegations established “extraordinary and compelling reasons” warranting a reduction in his sentence. 18 U.S.C. § 3582(c)(1)(A)(i). He also asserts that the district court erroneously considered U.S.S.G. § 1B1.13 to be binding. These contentions lack merit, as the district court’s assessment of the § 3553(a) factors furnished an independent and adequate basis for denying Tyler’s motion. See United States v. Escajeda, 58 F.4th 184, 188 (5th Cir. 2023); United States v. Rollins, 53 F.4th 353, 358 (5th Cir. 2022). Tyler additionally argues that the district court erred by perfunctorily denying his motion. Our remand to the district court cured the procedural deficiency. The district court noted overwhelming reasons as to why the § 3553(a) factors do not support a reduced prison term, based on Tyler’s repeated and longstanding drug trafficking, even while on supervised release. And the court found that the Section 3553(a) factors do not support early release based on defendant’s criminal history. sufficient. 2 This explanation was Case: 20-51011 Document: 00516942979 Page: 3 Date Filed: 10/24/2023 No. 20-51011 This court’s order denying early release is AFFIRMED. 3

Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.