Background
In February 2024, defendant Samuel Sweeley pleaded guilty to involuntary manslaughter and driving under the influence of alcohol. The district court sentenced him to thirty-three months of imprisonment followed by a three-year term of supervised release. Sweeley’s lawyer initially filed a brief pursuant to Anders v. California stating there were no meritorious grounds for appeal but questioned the substantive reasonableness of the sentence. The court identified a potentially meritorious issue regarding a drug testing payment condition that was orally pronounced but omitted from the written judgment.
The court’s reasoning
The court noted that Sweeley maintained there was no error because his written judgment omitted a burden that was orally pronounced. Sweeley argued that the discrepancy did not aggrieve him because he would objectively be better off without the added financial obligation. Consequently, the court decided to refrain from reaching the Rogers issue. The court carefully reviewed the entire record and found no other meritorious grounds for appeal.
What it means going forward
The conviction and sentence remain in effect. The court did not establish precedent regarding the discrepancy between oral pronouncements and written judgments in this specific instance due to the defendant’s position.
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