United States v. Deneen Sweeting, 213 F.3d 95 (3d Cir. 2000)

Author:

Publisher

University of California Press

Reference41 articles.

1. 1 The district court exercised subject matter jurisdiction pursuant to 18 U.S.C. s 3231, which provides that the district courts have original jurisdiction "of all offenses against the laws of the United States." We exercise appellate jurisdiction over the district court's final order pursuant to 28 U.S.C. s 1291, and have jurisdiction under 18 U.S.C. s 3742(b)(3) to review a final sentence where, as here, the sentence is less than the minimum sentence specified in the applicable Guidelines range.

2. 2 The genesis of section 5H1.6 lies in Congress' directive to the Sentencing Commission to "assure that the guidelines and policy statements . reflect the general inappropriateness of considering the . family ties and responsibilities . of the defendant." 28 U.S.C. s 994(e).

3. 3 We point out that the government does not challenge the accuracy of the evidence in the record concerning the nature of Sweeting's family ties and responsibilities - for example - the type of specialized care her son requires because of his condition. Rather, it asserts that the facts in the record do not warrant a downward departure because they do not demonstrate that her family situation is extraordinary in the sense contemplated by section 5H1.6. Similarly, for purposes of our analysis, we assume the accuracy of the historical facts in the record, but part company with the district court's ultimate factual conclusion that those circumstances render Sweeting's family ties and responsibilities so "extraordinary" so as to take this case out of the heartland of cases sentenced under the Guidelines. Moreover, it is appropriate to mention at this juncture that although our analysis of the nature of Sweeting's family responsibilities proceeds by examining each component of the district court's analysis separately, we have considered the cumulative effect of the totality of the circumstances presented in this case. And, as we have indicated in the text, we simply see no sound basis for upholding the district court's departure determination notwithstanding our deferential standard of review.

4. 4 Sweeting apparently recognizes that her son's condition is pivotal to the analysis of whether the district court erred in granting a departure under section 5H1.6 given her family situation. Importantly, this factor is the sole basis on which she argues in her brief that she faces "extraordinary" family responsibilities. See br. at 12 ("It is submitted that this mother's responsibilities for the care of an adolescent child with Tourette's Syndrome constituted an extraordinary family responsibility. For this reason, the district court did not abuse its discretion [in] granting the downward departure." ).

5. 5 We recognize, as Sweeting points out in her brief, that there are decisions by other courts of appeals that have upheld downward departures under section 5H1.6 where the circumstances demonstrated that the defendant was responsible for the care of a sick family member. She contends that those cases support her position because the defendants were responsible for the care of dependents, at least one of whom was disabled. We reject this argument, however, as we do not agree with Sweeting's assessment that the cases she cites are analogous to the factual situation presented here. Indeed, a review of the cases that she relies upon confirms that each had an additional factual component distinguishing it from this case. See, e.g.

Cited by 66 articles. 订阅此论文施引文献 订阅此论文施引文献,注册后可以免费订阅5篇论文的施引文献,订阅后可以查看论文全部施引文献

同舟云学术

1.学者识别学者识别

2.学术分析学术分析

3.人才评估人才评估

"同舟云学术"是以全球学者为主线,采集、加工和组织学术论文而形成的新型学术文献查询和分析系统,可以对全球学者进行文献检索和人才价值评估。用户可以通过关注某些学科领域的顶尖人物而持续追踪该领域的学科进展和研究前沿。经过近期的数据扩容,当前同舟云学术共收录了国内外主流学术期刊6万余种,收集的期刊论文及会议论文总量共计约1.5亿篇,并以每天添加12000余篇中外论文的速度递增。我们也可以为用户提供个性化、定制化的学者数据。欢迎来电咨询!咨询电话:010-8811{复制后删除}0370

www.globalauthorid.com

TOP

Copyright © 2019-2024 北京同舟云网络信息技术有限公司
京公网安备11010802033243号  京ICP备18003416号-3