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U.S. v. Fennell

United States Court of Appeals, Tenth Circuit
Aug 30, 1995
65 F.3d 812 (10th Cir. 1995)

Summary

holding that probation officer's testimony, which repeated "unsworn out-of-court statements made [over the phone] by an unobserved witness and unsupported by other evidence" could not sustain the defendant's sentence enhancement

Summary of this case from United States v. Colón-Maldonado

Opinion

No. 94-7179.

Filed August 30, 1995.

Submitted on the briefs:

The parties have agreed that this case may be submitted for decision on the briefs. See Fed.R.App.P. 34(f); 10th Cir. R. 34.1.2. After examining the briefs and appellate record, this panel has determined unanimously that oral argument would not materially assist the determination of this appeal. See Fed.R.App.P. 34(a); 10th Cir.R. 34.1.9. The case is therefore ordered submitted without oral argument.

Gene V. Primomo of Wilcoxen, Wilcoxen Primomo, Muskogee, Oklahoma, for Defendant-Appellant.

John Raley, United States Attorney, and Paul G. Hess, Assistant United States Attorney, Eastern District of Oklahoma, Muskogee, Oklahoma, for Plaintiff-Appellee.

Appeal from the United States District Court for the Eastern District Of Oklahoma.

(D.C. No. CR-94-37-S)

Before SEYMOUR, Chief Judge, McKAY and HENRY, Circuit Judges.


Pursuant to a plea bargain struck with the government, Mr. Fennell pled guilty to possession of an automatic machine gun in violation of 18 U.S.C. § 922(o) and 18 U.S.C. § 2. He does not here contest his guilt. Mr. Fennell does, however, take issue with the sentence imposed upon him by the district court. The presentence report, concluding that Mr. Fennell had used his machine gun in connection with a felonious assault, recommended a sentence based upon the four-level enhancement required by §§ 2K2.1(b)(5) of the Sentencing Guidelines. The district court, over the objections of Mr. Fennell, agreed that the evidence supported the enhancement and sentenced Mr. Fennell accordingly. Mr. Fennell appeals this ruling.

The district court found by a preponderance of the evidence that Mr. Fennell had fired his machine gun at his former girlfriend — an act which admittedly would constitute a felony within the meaning of §§ 2K2.1(b)(5). The district court based its finding upon the presentence report and upon the testimony of the probation officer who prepared that report. The report and the accompanying testimony, in turn, simply recounted statements made by the girlfriend to the preparing officer during a telephone interview. In essence, then, the district court's finding was based upon hearsay evidence.

Mr. Fennell acknowledges that reliable hearsay may be used in the determination of a sentence. See U.S.S.G. § 6A1.3 comment (1993); United States v. Beaulieu, 893 F.2d 1177, 1179-81 (10th Cir.), cert. denied, 497 U.S. 1038 (1990); see also United States v. Ortiz, 993 F.2d 204, 207-08 (10th Cir. 1993); United States v. Reid, 911 F.2d 1456, 1464 (10th Cir. 1990), cert. denied, 498 U.S. 1097 (1991). He contends, however, that the evidence relied upon by the district court lacks the minimal indicia of reliability required by the Sentencing Guidelines. See Beaulieu, 893 F.2d at 1181. We agree.

In United States v. Shepherd, 739 F.2d 510 (10th Cir. 1984), we indicated in dicta that at sentencing a district court could consider uncorroborated hearsay evidence which the defendant has had an opportunity to explain or rebut. See id. at 515. We note that Shepherd preceded the adoption of the Sentencing Guidelines.

During the sentencing hearing, the preparing officer admitted that the § 2K2.1(b)(5) enhancement was based solely upon unsworn allegations made by the girlfriend during the telephone interview. Tr., Vol. II, at 10-11. These statements might well be credible; potential truth, however, does not mitigate the almost total absence of indicia of reliability. The girlfriend did not prepare a sworn affidavit in support of her allegations. The preparing officer did not have an opportunity to observe her demeanor during the interview and therefore could not form any opinion as to her veracity. The Record, moreover, contains no other evidence that corroborates the account given the preparing officer. The facts surrounding Mr. Fennell's arrest, while suggesting that the machine gun was fired during an altercation between Mr. Fennell and his girlfriend, do not answer the question of whether Mr. Fennell's actions constituted a felony or a misdemeanor. It is significant, in this context, that state authorities originally charged Mr. Fennell with misdemeanor assault. Under Oklahoma law, an assault "with any kind of firearm" is a felony if it is accompanied by "the intent to do bodily harm" or the "intent to injure" someone. Okla. Stat. Ann. tit. 21, § 645. The decision to charge Mr. Fennell with misdemeanor assault therefore suggests that evidence of felonious intent was lacking at the time of arrest. The record itself, therefore, tends to undermine, rather than buttress, confidence in the girlfriend's hearsay statements.

The government did not bother to file the arrest report or even to summarize its contents with any particularity. We are thus unable to determine if the girlfriend's contemporaneous statements to the state police support the story given the preparing officer.

The girlfriend's unsworn allegations, therefore, stand as the only evidence of a felonious assault upon which the enhancement could be based. The Sentencing Guidelines do not set a high threshold of reliability, but more is required than was presented here. Unsworn out-of-court statements made by an unobserved witness and unsupported by other evidence form an insufficient predicate for a sentence enhancement under 2K2.1(b)(5). As these statements were the only evidence indicative of a felony, the enhancement itself was improper. We therefore reverse and remand this case to the district court with instructions to vacate Mr. Fennell's sentence and resentence him in accordance with this opinion.

REVERSED and REMANDED.


Summaries of

U.S. v. Fennell

United States Court of Appeals, Tenth Circuit
Aug 30, 1995
65 F.3d 812 (10th Cir. 1995)

holding that probation officer's testimony, which repeated "unsworn out-of-court statements made [over the phone] by an unobserved witness and unsupported by other evidence" could not sustain the defendant's sentence enhancement

Summary of this case from United States v. Colón-Maldonado

holding that probation officer's testimony, which repeated "unsworn out-of-court statements made [over the phone] by an unobserved witness and unsupported by other evidence" could not sustain the defendant's sentence enhancement

Summary of this case from United States v. Colón-Maldonado

holding that evidence the defendant fired a machine gun at his girlfriend lacked sufficient indicia of reliability because it was uncorroborated and the preparing officer, who spoke to the defendant's girlfriend only over the phone, "did not have an opportunity to observe her demeanor during the interview and therefore could not form any opinion as to her veracity"

Summary of this case from United States v. Villa

holding improper the finding of use and possession of firearm in prior felony based solely on hearsay statements

Summary of this case from U.S. v. Lynch

concluding sentencing hearsay evidence did not possess sufficient indicia of reliability because no sworn affidavit was prepared; the interview was conducted over the phone, depriving the officer of the opportunity to "observe [the victim's] demeanor"; and there was no other evidence in the record "corroborat[ing] the account given [to] the [PSR] preparing officer"

Summary of this case from United States v. Sheridan

reversing district court where sentencing enhancement was based solely on hearsay statement by defendant's ex-girlfriend with no other corroborating evidence

Summary of this case from United States v. Ruby

reversing district court where sentencing enhancement was based solely on hearsay statement by defendant's ex-girlfriend with no other corroborating evidence

Summary of this case from United States v. Ruby

reversing the district court's application of a § 2K2.1(b) enhancement because the factual evidence supporting its application was insufficient, not because of the type of charge pursued in a prior state court proceeding

Summary of this case from U.S. v. Philley

reversing a sentence where "the district court's finding [for a sentence enhancement] was based upon hearsay evidence"

Summary of this case from U.S. v. Blagg

reversing district court where sentencing enhancement was based solely on hearsay statement by defendant's ex-girlfriend with no other corroborating evidence

Summary of this case from United States v. Martinez

In Fennell, we concluded that the district court shouldn't have enhanced a sentence based on an unsworn, unobserved statement unsupported by other evidence. Fennell, 65 F.3d at 813.

Summary of this case from United States v. Young

In Fennell, we held unsworn testimony of a girlfriend taken over the telephone by a probation officer lacked "the minimal indicia of reliability required" by the Guidelines to alone support a sentencing enhancement for using a machine gun in connection with a felonious assault. Id. at 813; see United States v. Cook, 550 F.3d 1292, 1295 (10th Cir. 2008)

Summary of this case from United States v. Nunez-Romero

In Fennell, we determined that the evidence before the district court was insufficient to apply a sentence enhancement for possession of a machine gun.

Summary of this case from United States v. Lujan

remanding for resentencing after finding sentencing enhancement factually unsupported

Summary of this case from United States v. Richards

In Fennell, the court found a lack of reliability because an unsworn, out-of-court statement delivered via telephone from the defendant's former girlfriend was the only evidence in the record; nothing corroborated her story.

Summary of this case from United States v. Shalash

In Fennell, however, we noted that the girlfriend may have had a reason to lie based on her previous relationship with the defendant.

Summary of this case from United States v. Dickerson

In Fennell, we reversed a district court's four-level enhancement for using or possessing a firearm in connection with another felony.

Summary of this case from United States v. Martinez

In Fennell, we held that the unsworn testimony of a defendant's girlfriend used to support a sentencing enhancement lacked the required "minimal indicia of reliability" because the probation officer who prepared the presentence report took her testimony over the telephone and did not personally observe her demeanor such that he could determine her veracity, and no other evidence corroborated the girlfriend's unsworn testimony.

Summary of this case from United States v. Sedillo

In Fennell, we reviewed a sentence enhancement for possession of a machine gun based solely on his estranged girlfriend's unsworn telephone statement to a probation officer that the defendant had fired the machine gun at her.

Summary of this case from United States v. Ruby

In Fennell, we reviewed a sentence enhancement for possession of a machine gun based solely on his estranged girlfriend's unsworn telephone statement to a probation officer that the defendant had fired the machine gun at her.

Summary of this case from United States v. Ruby

In Fennell, we held that the unsworn testimony of a girlfriend taken over the telephone by a probation officer lacked "the minimal indicia of reliability required" by the Guidelines to support a sentencing enhancement.

Summary of this case from U.S. v. Cook

In Fennell, the only evidence presented supporting the enhancement was (1) a hearsay statement contained in the PSR made by the defendant's girlfriend during a telephone interview with the officer who prepared the PSR to the effect that the defendant had fired a machine gun at her, and (2) the testimony of that officer at the sentencing hearing that merely recounted the girlfriend's statement made during the interview.

Summary of this case from U.S. v. Norris

In Fennell, we held that where a defendant properly objects to a statement in a PSR, "[u]nsworn out-of-court statements made by an unobserved witness and unsupported by other evidence form an insufficient predicate for a sentence enhancement under 2K2.1(b)(5)."

Summary of this case from U.S. v. Norris

stating that "reliable hearsay may be used in the determination of a sentence"

Summary of this case from U.S. v. Curtis
Case details for

U.S. v. Fennell

Case Details

Full title:UNITED STATES OF AMERICA, Plaintiff-Appellee, v. QUINTON NEAL FENNELL…

Court:United States Court of Appeals, Tenth Circuit

Date published: Aug 30, 1995

Citations

65 F.3d 812 (10th Cir. 1995)

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