United States v. Mansfield, No. 20-2981 (7th Cir. 2021)
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Mansfield entered an open guilty plea to possession with intent to distribute methamphetamine. His PSR recommended an imprisonment range of 188-235 months and listed 26 “[o]ther [a]rrests” in 1992-2013, involving at least 49 charges, including domestic battery and battery resulting in bodily injury, resisting law enforcement, felony intimidation, neglect of a dependent, and drug possession charges culminating in two 2013 felony charges for “Dealing in Cocaine or Narcotic,” and three 2013 felony charges for “Possession of Cocaine or Narcotic.” The disposition for 48 charges was “Dismissed,” “No Action Taken,” or “Unknown.” A 1999 criminal trespass charge was listed as “Not guilty.”
Mansfield sought a downward departure but never challenged the accuracy of the PSR or the inclusion of Mansfield’s arrest history. Mansfield raised no objections at the sentencing hearing. The court referenced the parties’ statements, the sentencing memorandum, and the 18 U.S.C. 3553(a) factors, noting the presence of young girls at the drug bust, past leniency, evidence of Mansfield’s desire to improve, and the potential effects of COVID-19 on Mansfield’s health, with a two-sentence reference to Mansfield’s arrest history. The court pronounced a sentence of 188 months’ imprisonment. Mansfield raised no objections.
The Seventh Circuit affirmed. Mansfield waived his challenge to the court’s consideration of his arrest history. Even if this point was not waived, a substantial history of arrests, especially if they are similar to the offense of conviction, can be a reliable factor to consider at sentencing.
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