U.S. v. Adams, No. 16-2786 (MOORE, White, Donald).

U.S. v. Adams, No. 16-2786 (MOORE, White, Donald).

A defendant who had been addicted to opiates for several decades tested positive for opiates several times while on supervised release. The district court ultimately revoked his supervised release and sentenced him to a below-Guidelines term of incarceration of eighteen months. The defendant appealed, arguing that the sentence was both procedurally and substantively unreasonable.

The Sixth Circuit agreed, vacating the sentence and remanding for resentencing. The Court, relying on Circuit precedent, reiterated that a defendant has a due-process right to be sentenced based on accurate information, which right extends beyond the defendant’s own actions and criminal history. Because the district court relied on the Government’s unsupported, and therefore unreliable, proposition that long-term heroin addicts need eighteen months for their brain chemistry to “reset” in order for future treatment to be effective, the sentence was procedurally unreasonable.

The Court also found the defendant’s sentence substantively unreasonable because the district court calculated the length of the sentence for the purpose of promoting the rehabilitation of the defendant, in violation of the rule set out by the U.S. Supreme Court in Tapia v. U.S., 564 U.S. 319, 335 (2011).