As the Courts that have rejected Hecke's argument have noted, “the Guidelines reflect the harsh societal harms caused by the production, distribution, and use of pure methamphetamine as well as a legislative desire to address these harms with significant penalties.” United States v. Kaufman, 2019 WL 3220571 (D. Me. July 17, 2019).
United States v. Carrillo, 440 F.Supp.3d 1148, 1154-55 (E.D. Cal. 2020); United States v. Moreno, 583 F.Supp.3d 739, 745 (W.D. Va. 2019); United States v. Johnson, 379 F.Supp.3d 1213, 1226 (M.D. Ala. 2019); United States v. Rodriguez, 382 F.Supp.3d 892, 897-98 (D. Alaska 2019); United States v. Bean, 371 F.Supp.3d 46, 55-56 (D.N.H. 2019); United States v. Pereda, No. 1:18-cr-228, 2019 WL 463027, at *4 9 (D. Colo. Feb. 6, 2019); United States v. Ferguson, No. 0:17-cr-204, 2018 WL 3682509, at *4 (D. Minn. Aug. 2, 2018); United States v. Harry, 313 F.Supp.3d 969, 974 (N.D. Iowa 2018); United States v. Nawanna, 321 F.Supp.3d 943, 955 (N.D. Iowa 2018); United States v. Ibarra-Sandoval, 265 F.Supp.3d 1249, 1257 (D.N.M. 2017). But see United States v. Kaufman, No. 2:18-cr-36, 2019 WL 3220571, at *3 (D. Me. July 17, 2019). That holding is premised on four primary grounds: • The 10-to-1 actual-to-mixture ratio isn't grounded in any empirical evidence generated by the Sentencing Commission, • methamphetamine purity is no longer a useful proxy-if, indeed, it ever was-for the relative culpability of a defendant, • the 10-to-1 ratio creates unwarranted sentencing disparities among defendants convicted of methamphetamine crimes, and • the multiplier applied to defendants convicted of crimes involving methamphetamine (actual) creates unwarranted sentencing disparities between those defendants and those convicted of other drug crimes.