United States v. Watts case brief

 United States v. Watts

1. 1. Issue: Whether a sentencing court may consider conduct of the defendant’s underlying charges, of which they have been acquitted.
   2. Facts:
      1. Jury convicted Watts of possessing cocaine with intent to distribute.
      2. Watts was acquitted on the charge that he used a firearm in relation to the drug offense (beyond a shadow of a doubt standard).
      3. The District Court found by a preponderance of the evidence that Watts DID possess the guns in connection with the drug offense and added to points to Watts’ base level offense.
      4. Watts argued that allowing the increase would effectively punish him for an offense he had been acquitted of.
   3. Holding and Analysis:
      1. 18 USC §3661  NO LIMITATION shall be placed on the information concerning background, character, and conduct of a person which a court may receive and consider when imposing a sentence.
      2. “Accordingly, the Guidelines conclude that ‘[r]elying on the entire range of conduct, regardless of the number of counts that are alleged or on which a conviction is obtained, appears to be the most reasonable approach to writing workable guidelines for these offenses.’