5th Cir.

United States v. Phillips

May 28, 2026 ·25-30067 ·Panel Decision ·Cory T. Wilson · By James Taylor

The Fifth Circuit affirmed a defendant's sentence after determining that a high-speed car chase constituted violence under the federal sentencing safety valve. The court held that fleeing at speeds exceeding one hundred thirty-five miles per hour and striking another vehicle satisfied the statutory bar to relief.

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Background

James Troy Phillips led police on a high-speed car chase exceeding one hundred thirty-five miles per hour while transporting marijuana. He struck another vehicle during the pursuit before being arrested and pleading guilty to conspiracy to distribute and possess with intent to distribute marijuana. At sentencing, the district court imposed a sixty-month sentence based on a five-year mandatory minimum, initially failing to articulate why it denied Phillips’s request for safety valve relief.

The court’s reasoning

The Fifth Circuit reviewed the district court’s interpretation of the safety valve statute de novo. The court agreed with the district court’s remand explanation that Phillips used violence within the meaning of Section thirty-five fifty-three subsection f paragraph two. The court found that operating a motor vehicle at extreme speeds while fleeing law enforcement, coupled with a collision, involved force capable of causing serious bodily injury. The court relied on Seventh Circuit precedent in United States versus Harden, noting that high-speed vehicular flight poses a real threat of physical injury and that the collision here represented an actual application of physical force.

Phillips’s high-speed car chase subjected himself and others to an extremely high risk of serious physical injury.

United States v. Phillips, 25-30067 (5th Cir. May 28, 2026)

What it means going forward

Defendants who engage in high-speed vehicular flight to evade law enforcement and cause collisions will likely be barred from receiving sentencing safety valve relief, ensuring that mandatory minimum sentences apply in drug trafficking cases.

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