Background
Myyeshia Taylor appealed her conviction and sentence for being a felon in possession of a firearm in violation of Section eighteen of the United States Code, Section nine hundred twenty-two, subsection g. She raised multiple arguments regarding the district court’s application of the Sentencing Guidelines and alleged prosecutorial misconduct during the trial.
The court’s reasoning
The court held that the use of acquitted conduct at sentencing does not violate the Sixth Amendment under controlling precedent. Regarding the obstruction of justice enhancement, the court found that the district court failed to make express findings on all three prongs of the perjury definition, specifically the willful intent element. The court concluded that the district court’s cursory reference to the government’s sentencing memorandum did not satisfy the obligation to make independent findings. The court also determined that any errors regarding testimony about post-arrest silence and credibility did not affect Taylor’s substantial rights.
The dissent
What it means going forward
The decision clarifies that district courts must make explicit, independent findings regarding the willful intent element when applying obstruction of justice enhancements based on perjury, ensuring that such enhancements are not applied based on cursory references to government arguments.