United States v. Allen, No. 22-2158 (6th Cir. 2024)
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The case involved defendant Antwaun Allen who was found guilty of possessing methamphetamine with the intent to distribute. The defendant had been involved in a police sting operation where he sold methamphetamine to a confidential informant. At sentencing, he requested a downward variance from his Guidelines range, arguing the government's role in his offense, criticizing the Guidelines' treatment of meth purity, and pointing out mitigating offense and character traits. Ultimately, he was sentenced to 108 months, at the bottom of his Guidelines range.
On appeal, Allen puts forth three arguments: (1) his sentence is procedurally unreasonable as the district court failed to address the government's provocation of his offense, (2) his sentence is procedurally unreasonable because the district court ceded its sentencing discretion to Congress, and (3) his sentence is substantively unreasonable because the district court relied solely on the meth's weight and purity, neglecting his "whole person."
The United States Court of Appeals for the Sixth Circuit rejected all three arguments. The court held that the district court properly addressed all non-frivolous arguments raised by Allen, did not cede its discretion to Congress, and did not abuse its discretion in weighing sentencing factors. The court affirmed Allen's sentence of 108 months.
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