Background
Terrence Taylor, Sr., appealed a 210-month sentence imposed after a guilty plea for conspiracy to possess with intent to distribute methamphetamine. He challenged the district court’s drug quantity calculation, the substantive reasonableness of the sentence, and the constitutionality of the sentence under the Eighth Amendment.
The court’s reasoning
The court reviewed the drug quantity calculation for clear error and found the district court did not err in adopting presentence report findings and inferring purity levels for untested methamphetamine based on tested samples. The court dismissed the challenge to substantive reasonableness because Taylor waived that right in his plea agreement. The Eighth Amendment claim was rejected as conclusory and failing to show clear or obvious error under plain-error review.
What it means going forward
The ruling reinforces the Fifth Circuit’s deference to district court drug quantity calculations based on reliable presentence reports and enforces appeal waivers in plea agreements to bar substantive reasonableness challenges.