United States v. William Dale Wooden (6th Cir. December 2019)

The Court held that the defendant's consent for an undercover officer to enter his house was not tainted by "police deception." While the officer did not identify himself as law enforcement to the defendant when he asked to talk to the defendant's wife and to step inside "to get out of the cold," the officer did not take any affirmative acts to conceal his identity from the defendant. The Court also held that Wooden’s burglary convictions under Georgia law qualified as crimes of violence under the ACCA.

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United States v. Fareed Mumuni (2d Cir. December 2019)

Despite the significant amount of discretion granted to sentencing courts, the Court held that the district court’s downward variance of 80% from a Guidelines range of 85 years in prison to 17 years in prison was substantively unreasonable based on the Court of Appeals finding that the district court improperly second-guessed the defendant’s state of mind, created an unwarranted disparity between the defendants, and placed too much weight on mitigating factors.

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United States v. Tyrone Mitchell (3rd Cir. December 2019)

The Court held that the sentencing court committed plain and reversible error when it relied on the defendant’s “bare arrest record” in determining a sentence, as the sentencing court had only cited the Defendant’s “extensive criminal history” without adequately distinguishing between adjudications, convictions, and mere arrests. 

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