United States v. Kaufman

2 Citing cases

  1. United States v. Hecke

    1:20-CR-7-HAB (N.D. Ind. May. 4, 2023)

    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).

  2. United States v. Havel

    4:21-CR-3075 (D. Neb. Feb. 10, 2023)   Cited 20 times

    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.