Background
The defendant, Lorina Ann Fejeran, pleaded guilty to conspiracy to distribute methamphetamine and engaging in monetary transactions with proceeds of unlawful activity. She appealed her one hundred twenty-month sentence, challenging the district court’s handling of objections to the presentence report and its denial of safety-valve relief.
The court’s reasoning
The court held that the district court violated Federal Rule of Criminal Procedure thirty-two by failing to rule on disputed factual assertions regarding the defendant’s role in the offense. The court noted that the district judge merely overruled objections as a matter of law without making findings or stating the matters were irrelevant. Additionally, the court found the denial of safety-valve relief erroneous because the record was unclear on the basis for the decision and the court failed to provide reasons as required by statute.
What it means going forward
Sentencing courts must now explicitly resolve factual disputes in presentence reports and provide detailed reasons when denying safety-valve relief to ensure meaningful appellate review.