Fifth Circuit Holds District Court's Relevant Conduct Ruling Insufficient Stubblefield

Stubblefield appealed her 360-month sentence imposed after her guilty plea to conspiracy to distribute methamphetamine. When calculating the base offense level, the district court held Stubblefield responsible for all methamphetamine attributable to the conspiracy under U.S.S.G. 1B1.3. Stubblefield argued that the district court failed to make sufficient factual findings to support its relevant conduct findings.

In order to hold Stubblefield accountable for the 630 grams of methamphetamine involved in the conspiracy, the district court was required to make specific findings that the acts and omissions of the others involved constituted relevant conduct-that is, that the other transactions were within the scope of a joint criminal activity, in furtherance of that activity, and reasonably foreseeable to Stubblefield.

At sentencing, the district court determined that the entire 630 grams of methamphetamine attributed to the conspiracy was reasonably foreseeable to Stubblefield, but the court failed to make specific findings concerning the scope of the criminal activity, or whether the entire amount of methamphetamine was within that scope or in furtherance of that activity.

Additionally, the Fifth Circuit concluded that the district court’s rationale for its relevant conduct determination was not implicit in its adoption of the presentence report, which did not make factual findings that would allow making Stubblefield accountable for jointly undertaken criminal activity.

Because the district court’s reasoning was not apparent from the record, the Fifth Circuit held it could not speculate as to the rationale for its relevant conduct determination. Accordingly, the court vacated Stubblefield’s sentence and remanded to the district court for resentencing.