United States v. Woodside

Woodside, a Florida resident, participated in a 24-person conspiracy to distribute pain pills in Middle Tennessee. He pled guilty under 21 U.S.C. 841 and 846. The Sixth Circuit vacated his 170-month so that the district court might better explain the quantity of drugs attributable to him. On remand, the district court, without further hearing, imposed the same sentence and explained its reasoning—including the drug quantity on which it based Woodside’s sentence—in a written amended judgment. The Sixth Circuit affirmed, rejecting Woodside’s argument that the district court erred by not affording him a new sentencing hearing and violated 18 U.S.C. 3553(c) by not stating the new explanation for his sentence “in open court.” The limited remand did not entitle Woodside to a new sentencing hearing or new procedures. Even if the district court erroneously attributed to Woodside drugs sold by others, Woodside would still have been sentenced according to the same base-offense level; any error was therefore harmless. View "United States v. Woodside" on Justia Law