United States v. Amon Sudan Sanders-Outlaw
Court
Sixth Circuit Court of Appeals
Decided
June 6, 2025
Jurisdiction
F
Practice Areas
Case Summary
NOT RECOMMENDED FOR PUBLICATION File Name: 25a0279n.06 No. 24-1408 UNITED STATES COURT OF APPEALS FILED FOR THE SIXTH CIRCUIT Jun 06, 2025 KELLY L. STEPHENS, Clerk ) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE WESTERN ) DISTRICT OF MICHIGAN AMON SUDAN SANDERS-OUTLAW, ) Defendant-Appellant. ) OPINION ) ) Before: BATCHELDER, GIBBONS, and BLOOMEKATZ, Circuit Judges. BLOOMEKATZ, Circuit Judge. Amon Sudan Sanders-Outlaw pleaded guilty to conspiring to sell drugs. At sentencing, the district court counted one of Sanders-Outlaw’s prior offenses—a drug-trafficking conviction from state court—toward his criminal history score. That raised his advisory Sentencing Guidelines range. The district court then imposed a within- Guidelines sentence of 168 months of imprisonment. Sanders-Outlaw now appeals his sentence. He argues that his criminal history score should not have included his state conviction because it involved “relevant conduct” to his federal offense. But Sanders-Outlaw hasn’t shown that his past and present offenses were sufficiently connected. We affirm. BACKGROUND Sanders-Outlaw’s appeal implicates two of his convictions: a past conviction from state court, and the present conviction in federal court. We describe both here, construing the facts, which Sanders-Outlaw does not dispute, as the district court did. No. 24-1408, United States v. Sanders-Outlaw I. State Offense In May 2021, police investigated Anthony Sanders, who is Sanders-Outlaw’s brother, for possible drug trafficking. During the investigation, police had confidential informants buy drugs directly from Sanders at least twice. One of those buys occurred at an apartment in Kentwood, Michigan. Soon after, police applied for a warrant to search the apartment. On the day they planned to execute the warrant, while surveilling that apartment beforehand, law enforcement saw Sanders- Outlaw leave the building, walk to a car in the parking lot, appear to sell drugs to the driver, and return to the apartment. Police then executed the warrant. Inside the apartment, they arrested Sanders-Outlaw. They seized cash, fentanyl, methamphetamine, phones, and a gun. Police also arrested a man named Anthony Mcconer, who had left the apartment before they searched it. The police interviewed the apartment’s tenant, Mcconer’s girlfriend. She told police that Sanders-Outlaw had flushed drugs down the toilet before the police arrived and that she believed the gun belonged to him. She also said that she thought Sanders had been supplying drugs to Sanders-Outlaw and Mcconer. Police searched one of the phones from the apartment and determined that it belonged to Sanders. The phone contained videos and photos showing Sanders, drugs, money, and guns. Police had also seized a phone from Sanders-Outlaw when they arrested him. When they searched Sanders-Outlaw’s phone, they found text-message conversations in which he appeared to tell customers that he was no longer working for his brother and that prices would be changing as a result. Sanders-Outlaw pleaded guilty in state court to delivery of methamphetamine. The state court sentenced him to a term of thirty months to twenty years in custody. -2- No. 24-1408, United States v. Sanders-Outlaw II. Federal Offense After Sanders-Outlaw had been arrested but before he had been sentenced in state court, law enforcement started a new drug-trafficking investigation of Sanders. Officers arranged for undercover individuals and confidential informants to buy fentanyl and methamphetamine from Sanders. They carried out transactions, once directly with Sanders, twice with another accomplice, and four times with Sanders-Outlaw, who was delivering on Sanders’s behalf. Sanders-Outlaw told an undercover officer during a February 2023 buy that he and his brother were “like a tag team.” Compl., R. 1-1, PageID 20. In April 2023, officers executed a search warrant a
Case Details
Case Details
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Status
Decided
Date Decided
June 6, 2025
Jurisdiction
F
Court Type
appellate
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Case Summary
AI-generated comprehensive summary with legal analysis
Case Overview
In the case of United States v. Amon Sudan Sanders-Outlaw, the defendant appealed his sentencing, arguing that his prior state drug conviction should not have been included in his criminal history score. The appeal was decided by the Court of Appeals for the Sixth Circuit on June 6, 2025.
Legal Issues
The court addressed several critical legal issues:
- Whether the district court erred in including Sanders-Outlaw's state conviction in his criminal history score.
- Whether Sanders-Outlaw's 2021 and 2023 offenses constitute a common scheme or plan.
- Whether Sanders-Outlaw's 2021 drug offense is part of the same course of conduct as his current conviction.
Factual Background
- Key Facts:
- Sanders-Outlaw's state conviction involved drug trafficking and occurred in May 2021, while the federal offense occurred in 2023.
- A twenty-month gap existed between the two offenses, with different victims and accomplices involved.
This background was crucial in determining the relevance of the prior conviction to the current sentencing.
Court's Analysis
The court's reasoning included:
- The district court's decision to include the state conviction was based on the significant gap in time and operational differences between the offenses. The court referenced U.S.S.G. § 4A1.2(a)(1) and its commentary regarding relevant conduct.
- The court found insufficient evidence of a common scheme or plan due to a lack of connection between the offenses, as per U.S.S.G. § 1B1.3 cmt. n.5(B)(i). The twenty-month gap indicated weak temporal proximity, leading to the conclusion that the offenses did not constitute the same course of conduct.
Holdings and Decision
The court made the following holdings:
- The district court did not err in including Sanders-Outlaw's state conviction in his criminal history score.
- Sanders-Outlaw's 2021 and 2023 offenses do not constitute a common scheme or plan.
- Sanders-Outlaw's 2021 offense is not part of the same course of conduct as his current conviction.
Legal Precedents
The court cited several precedents:
- U.S. v. Rayyan, 885 F.3d 436 (6th Cir. 2018): Established the standard of review for sentencing decisions.
- U.S.S.G. § 1B1.3: Defines relevant conduct in the context of sentencing.
- United States v. Easley, 306 F. App’x 993 (6th Cir. 2009): Supported the argument regarding the lack of a continuing scheme.
- Hill, 79 F.3d 1483 (6th Cir. 1996): Emphasized the need for a high degree of similarity to overcome temporal gaps.
Practical Implications
This ruling has significant implications for legal practice, particularly in the areas of criminal law, sentencing, and appeals. It clarifies how prior offenses are assessed under the Sentencing Guidelines, particularly regarding relevant conduct and the criminal history score. Future cases may rely on this decision to argue for or against the inclusion of past convictions based on the connections between offenses.
Overall, the Sixth Circuit's decision reinforces the importance of temporal proximity and the nature of prior offenses in determining sentencing outcomes.
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Case Details
Legal case information
Status
Decided
Date Decided
June 6, 2025
Jurisdiction
F
Court Type
appellate
Legal Significance
Case importance metrics
Metadata
Additional information
Quick Actions
Case management tools