Sixth Circuit Affirms 198-Month Sentence for Cocaine Conspiracy After District Court Rejected Plea Deal

Brown was convicted by a jury after two plea agreements were rejected by the district court. The underlying investigation began in July 2022 when Louisville Metro Police observed Brown near a vehicle with a handgun. A subsequent traffic stop and cell phone tracking led officers to a house where Brown, along with Axel Diaz-Hernandez and Clarence Stott, was involved in packaging narcotics.

Surveillance revealed the men moving items between vehicles and using a hidden compartment in a car’s wheel well. Officers later recovered a kilogram of cocaine from Diaz-Hernandez’s truck and $59,110 in cash from the hidden compartment in the car Brown had driven. A search of the house yielded 6.9 kilograms of cocaine, money counters, and vacuum-sealing supplies.

Brown initially entered a guilty plea under a Rule 11(c)(1)(C) agreement stipulating to a 60-month sentence. The district court deferred its decision until after the presentence investigation report calculated a Guidelines range of 130 to 162 months. The court rejected the agreement, finding the parties had not provided adequate justification for the significant variance from the low end of the Guidelines range.

The parties presented a second agreement recommending 72 months, which the court also rejected for the same reasons. Brown withdrew his guilty plea and proceeded to trial, where he was convicted on both counts and sentenced to 198 months followed by six years of supervised release.

On appeal, Brown argued the district court erred in rejecting the plea agreements. The Sixth Circuit held that the district court provided a sufficient explanation for the rejections, noting that the court did not feel it had the necessary information to justify a sentence significantly lower than the Guidelines range. The appellate court affirmed the judgment under both abuse of discretion and plain error standards.

Brown also challenged the denial of a Franks hearing and the admission of an AutoZone receipt showing a purchase of J-B Weld glue, which was used to seal the hidden compartment. The Sixth Circuit held that none of these arguments had merit and affirmed the district court’s judgment.