By Evelyn Norton
Today, in the criminal case of United States v. Meredith, an unpublished per curiam opinion, the Fourth Circuit affirmed the decision of the U.S. District Court for the Northern District of West Virginia sentencing Ms. Loretta Meredith to one year and one day of imprisonment.
Defendant Challenged the Sentence Imposed
The District Court found Ms. Meredith guilty of conspiring to knowingly and corruptly attempt to obstruct, influence, and impede an official proceeding, thus violating 18 U.S.C. § 1512(c)(2) and (k).
On appeal, counsel for Ms. Meredith argued that the District Court: (1) wrongly increased the base offense level for Ms. Meredith’s Guidelines range for substantially interfering with the administration of justice; (2) clearly erred in increasing the base offense level for Ms. Meredith’s Guidelines range because the offense was extensive in scope, planning, or preparation; and (3) imposed an unreasonable sentence.
The Fourth Circuit reviewed the District Court’s factual findings for clear error and legal conclusions de novo.
Defendant Did Substantially Interfere with the Administration of Justice
First, the Fourth Circuit considered whether the District Court wrongly increased the base offense level for Ms. Meredith’s Guidelines range for substantially interfering with the administration of justice. The Court observed that the U.S. Sentencing Guidelines Manual § 2J1.2 comment 1 states that “substantial interference with the administration of justice” includes “unnecessary expenditure of substantial governmental or court resources.” Here, the Court found that the record showed that significant government resources were invested to resolve Ms. Meredith’s attempts to obstruct justice. Thus, the Court concluded that the District Court properly increased Ms. Meredith’s offense level.
Defendant’s Attempts to Obstruct Justice Were Extensive
Second, the Fourth Circuit considered whether the District Court clearly erred in increasing the base offense level for Ms. Meredith’s Guidelines range because the offense was extensive in scope, planning, or preparation. Upon review of the record, the Court concluded that Ms. Meredith’s attempts to obstruct justice were, in fact, extensive in scope, planning, or preparation. Thus, the Court held that the District Court also properly applied the sentencing enhancement.
Defendant’s Sentence Is Reasonable
Third, the Fourth Circuit considered whether the District Court abused its discretion in imposing an unreasonable sentence. The Court found that Ms. Meredith’s sentence was not procedurally unreasonable because the District Court properly calculated the Guidelines range and considered the appropriate factors. Furthermore, the Court found that Ms. Meredith failed to meet the defendant’s burden to rebut the presumption on appeal that the sentence was substantively unreasonable. Thus, the Court concluded that the District Court did not impose an unreasonable sentence.
Holding
The Fourth Circuit affirmed the District Court’s decision sentencing Ms. Meredith to one year and one day of imprisonment for conspiring to knowingly and corruptly attempt to obstruct, influence, and impede an official proceeding.
