Matthew Charles

UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF TENNESSEE

NASHVILLE DIVISION
UNITED STATES OF AMERICA )

) NO. 3:96-CR-00051
v. ) JUDGE TRAUGER
)
MATTHEW OTIS CHARLES )
DEFENDANT’S SENTENCING MEMORANDUM

AND, IN THE ALTERNATIVE, MOTION TO INITIATE HOLLOWAY RELIEF
Defendant Matthew Charles respectfully requests that the Court, at the sentencing hearing,
determine that it is not bound to impose any certain sentence by any instruction of the Sixth
Circuit, and that it instead impose a 292-month sentence. He also asks that the Court conclude
that, in the special circumstances of this case, a sentence of 420 months would be cruel and
unusual, and thus prohibited by the Eighth Amendment. Finally, in the alternative, he asks that
the Court formally request that the U.S. Attorney agree to relief under the procedure set forth by
United States v. Holloway, 68 F.Supp.3d 310 (E.D.N.Y. 2014).
Statement of Facts
Because Charles has already recited most of the factual background in his previous
pleadings (Response, R.212, PageID # 1-6; Sentencing Memo, R.197), he will only highlight two
additional points.
1. Charles has not only reformed, but he has developed into an unusually
virtuous person.
Charles is attaching letters from his employer, from the director of the pantry where he
volunteers, from his pastor, and from other members of the community. (Ex. 1, Collective Letter
Exhibit.) They unequivocally vouch for his character. In detail they describe how Charles, in his
daily life, humbly goes above and beyond to help others. They say it literally sickens them to
Case 3:96-cr-00051 Document 220 Filed 12/07/17 Page 1 of 11 PageID #: 553

think of this thoroughly virtuous man having to return to prison for at least nine more years. 1
2. Had only a few immaterial words been uttered at Charles’s sentencing

hearing, he would not be facing more years in prison.
When Judge Sharp reduced Charles’s sentence under 18 U.S.C. § 3582(c)(2), he compared
Charles’s case to that of Larry Turnley. (Mem. Order, R.187, PageID # 171-72.) Turnley was
sentenced in 1997 for trafficking 20 kilograms of powder cocaine and 522 grams of crack cocaine.
(Ex. 2, Turnley Order at 1-2.) His guideline range under the drug guideline, U.S.S.G. § 2D.1, was
360 months to life. (Id. at 2.) His presentence report opined that he qualified as a “career
offender” and, under that guideline, U.S.S.G. § 4B1.1, his range was likewise 360 months to life.
(Id.) At sentencing, Turnley’s lawyer made a cursory and immaterial objection to his career-
offender classification. (Id. at 3.) The sentencing judge said it wasn’t necessary to address that
objection, which he then disregarded as moot; the judge imposed a life sentence, probably because
Turnley’s record involved two separate assault convictions where he had either shot at or pointed
a gun at police. (Id.; see Govt. Sentencing Memo, R.674, PageID # 522-23 (Case No. 3:96-cr-
120-4).)
Years later, Turnley, like Charles, filed for relief under § 3582(c)(2) because his § 2D1.1
range had been lowered after Congress and the Sentencing Commission recognized their crack-
cocaine penalties were needlessly draconian. Thanks to defense counsel’s immaterial and
unadjudicated objection to the career-offender classification back in 1997, the path was cleared for
the sentencing judge to reduce Turnley’s life sentence to 292 months. (Ex. 2, Turnley Order at 6-
7.) That was so because the lawyer’s objection made it clear that Turnley’s original sentence had
been “based on” the drug guideline, not the career-offender guideline. 18 U.S.C. § § 3582(c)(2).
1
If sentenced to 420 months, Charles will have 128 months left to serve. Assuming a 15%
reduction for good-time credits, Charles would have to serve about nine calendar years.
2

The government did not even find that ruling worthy of an appeal. 2
Charles followed the same path to relief as Turnley. The only difference – besides the fact
that Charles was responsible for a lot less cocaine than Turnley and that Charles had not shot at
the police – was that Turnley’s lawyer made a pointless objection at sentencing that the judge
treated as moot. Charles’s lawyer didn’t make that immaterial objection, and consequently courts
today can say his sentence wasn’t “based on” the drug guideline. 18 U.S.C. § 3582(c)(2). Had a
few meaningless words been uttered at Charles’s sentencing in 1996, his 292-month sentence
would, like Turnley’s, have stood, and Charles would certainly remain a free man. This fact – this
arbitrary distinction – only exacerbates the sickness that Charles’s community feels when thinking
of him returning to prison for at least nine more years.
Argument
I. The Sixth Circuit’s instructions do not preclude a resentencing under § 3553.
Charles will very briefly reiterate the legal context of his resentencing. When Judge Sharp
reduced his sentence, Charles got a new sentence that replaced the old one. United States v.
Bowers, 615 F.3d 715, 722-23 (6th Cir. 2010). After Rule 35’s 14-day window had passed, the
only route for the government get that sentence increased – absent discovery of a clerical error,
see Fed. R. Crim. P. 36 – was for the government to appeal under 18 U.S.C. § 3742, and not under
28 U.S.C. § 1291. Id. at 719; see also, e.g., United States v. Ross, 245 F.3d 577, 586 (6th Cir.
2001) (“[I]n the absence of an express statute or rule to the contrary, a district court is without
jurisdiction to reconsider and ultimately reimpose a modified term of imprisonment.”) The
2
Although the government appealed, it did not challenge that ruling. Rather, it only challenged
the court’s decision that it was free to vary below the bottom of the range and thus could sentence
Turnley to 240 months. United States v. Turnley, 627 F.3d 1032, 1033-34 & 1038 (6th Cir. 2010).
That decision was reversed on appeal, and on remand Turnley was sentenced to 292 months.
(Years later, that sentence was again reduced under § 3582(c)(2) due to another ameliorative
amendment to the guidelines, leaving Turnley with a sentence of 240 months.)
3

government took that route, and it won.
When the Sixth Circuit ruled in the government’s favor, it could not itself impose on
Charles a new sentence of 420 months. See United States v. Moody, 770 F.3d 577, 580 (7th Cir.
2014) (“The Sentencing Reform Act of 1984 removed any discretion we previously may have had
to correct an illegal sentence and compels a remand to the district court for resentencing.”).
Rather, it had to remand under the power afforded it by 18 U.S.C. § 3742, which directs that an
appellate court “shall remand to case for further sentencing proceedings with such instructions as
the court considers appropriate.” 18 U.S.C. § 3742(f)(1); see 18 U.S.C. § 2106 (providing
appellate courts with remedial powers); see generally Greenlaw v. United States, 554 U.S. 237,
248-49 (2008) (confirming that § 3742 can serve to limit the remedial powers of the Courts of
Appeals). Section 3742(g) specifies that, at these further sentencing proceedings, the district court
will act in accordance with both the appellate court’s instructions and 18 U.S.C. § 3553, which,
inter alia, reminds the district court to impose a sentence within the statutory sentencing range.
An appellate court’s instructions cannot override the limitations that § 3742 puts on its powers.
See Greenlaw, 554 U.S. at 249.
With this mandatory sentencing hearing on the horizon, the Sixth Circuit said only the
following in its mandate: “For these reasons, we vacate the district court’s judgment and remand
for purposes of entering an order that rejects Charles’ § 3582(c)(2) motion.” (Opinion, R.203,
PageID # 368.) Simply put, it said to deny the § 3582(c)(2) motion, and it was silent with respect
to the further sentencing proceedings that had to take place.
How should the Court read this silence? There are two possibilities. Perhaps the appellate
court assumed a 420-month sentence would impose itself or that the district court had inherent
powers to reinstate a former sentence outside the § 3553-compliant resentencing procedure
mandated by § 3742(g). Those assumptions, however, would conflict with Bowers, supra, and the

dictates of § 3742(f). Or perhaps the appellate court correctly assumed this Court would
resentence Charles in accordance with § 3553 and that this Court would decide how to handle that
resentencing procedure in the first instance.
That latter interpretation is favored by the principles for interpreting a mandate. For
starters, the base assumption is that the district court will handle the resentencing independently in
the first instance: “[A] district court can review sentencing matters de novo unless the remand
specifically limits the lower court’s inquiry.” United States v. Obi, 542 F.3d 148, 154 (6th Cir.
2008). Indeed, for a remand to specifically limit the resentencing court, it must “explicitly outline
the issues to be addressed by the district court and create a narrow framework within which the
district court must operate.” Id. Ambiguity does not bind: “The language used to limit the
remand should be, in effect, unmistakable.” Id.
It is not unmistakably clear that the Sixth Circuit erroneously assumed that a 420-month
sentence could reimpose itself or that this Court had an inherent power to reinstate it outside the
structure of §§ 3553 and 3742(g). Although the Sixth Circuit clearly created a “narrow
framework” for addressing the § 3582(c)(2) motion, it did not dictate away the § 3553
resentencing procedure. Cf. Greenlaw, 554 U.S. at 249 (limiting appellate court powers in face of
§ 3742). Nor did its complete silence with respect to resentencing “specifically limit” what could
happen at that resentencing. Obi, 542 F.3d at 154. The Court should assume that the appellate
court was aware of the statutory scheme that limited its power and that it was leaving the
mandated “further sentencing proceedings” to this Court.
II. At a resentencing under § 3553, it would be illegal to impose a 420-month

sentence.
For the reasons given previously, Charles maintains that at a resentencing under § 3553,
the rules of Apprendi and Booker would apply. Consequently, the maximum possible sentence for

Counts 1, 4, and 7 would be 240 months each, 3 and the Court would be free to vary downward
from the range of 360 months to life. Charles requests a sentence of 292-months.
III. It would violate the Eighth Amendment to impose a sentence of 420 months.
In any event, this Court is not authorized to impose a sentence that is unconstitutional.
The Eighth Amendment prohibits the infliction of “cruel and unusual punishments.” U.S. Const.
amend VIII. Central to this prohibition is the requirement that the punishment for the crime “be
graduated and proportioned to the offense.” Graham v. Florida, 560 U.S. 48, 59 (2010). “A
sentence lacking any legitimate penological justification is by its nature disproportionate to the
offense.” Id. at 71. “Even one day in prison would be a cruel and unusual punishment for the
‘crime’ of having a common cold.” Robinson v. California, 570 U.S. 661, 667 (1962). For
example, the U.S. Supreme Court struck down a 90-day sentence for being a drug addict. Id. The
D.C. Circuit recently struck down a 30-year sentence under 18 U.S.C. § 924(c), explaining: “none
of the penological justifications our society relies upon when sentencing criminals . . . are properly
served here by a sentence whose length is determined solely based on the type of weapon used
during the crime.” United States v. Slatten, 865 F.3d 767, 818 (D.C. Cir. 2017).
Charles raises an “as applied” Eighth Amendment challenge to a 420-month sentence. The
imposition of such a long sentence would be cruel and unusual based on “all the circumstances in
[this] particular case.” Graham, 560 U.S. at 59. That sentence would be “disproportionate to the
offense” because “lacking any legitimate penological justification,” as follows. Id. at 71.
1. Retribution. Charles is being sentenced for having sold 216 grams of crack cocaine.
Back when he sold it, the statutory penalties were wrongfully elevated due to the 100:1 crack-to-
powder ratio. Society and Congress have since recognized not only that the 100:1 ratio was
3
As mentioned previously, Charles has already fully served his valid sentences on all other
counts, and therefore it would violate Double Jeopardy to sentence him on them again. Ex Parte
Lange, 85 U.S. 163 (1873); see generally United States v. Adams, 362 F.2d 210 (6th Cir. 1966).
6

empirically unsound but that it was wrongful because of its disproportionate impact on African-
Americans. Dorsey v. United States, 132 S. Ct. 2321, 2325, 2328 (2012). 4 Due to the Fair
Sentencing Act, the maximum penalty allowed by law for Charles’s crime is now 40 years, not
life, and his guidelines range is much reduced. The Sentencing Commission and the Courts have
also recognized that the career-offender guideline is excessively harsh. See Id. and footnote 4,
supra. As a starting point, it should be recognized that a 35-year sentence for street-levels sales of
216 grams of crack cocaine (much of which was “ghost dope”) is needlessly severe. See, e.g.,
4
Members of Congress expressly recognized that the ratio both lacked evidentiary basis and had a
racially disparate impact. See, e.g., 155 Cong. Rec. S10491 (daily ed. Oct. 15, 2009) (statement of
Sen. Durbin) (“‘Each of the myths upon which we based the disparity has since been dispelled or
altered.’” (quoting Vice President Joe Biden, one of the authors of the legislation); id. S10492
(statement of Sen. Sessions) (the “current system is not fair” and “we are not able to defend the
sentences that are required to be imposed under the law today”); 156 Cong. Rec. S1683 (daily ed.
Mar. 17, 2010) (statement of Sen. Leahy) (“This policy is wrong and unfair, and it has needlessly
swelled our prisons, wasting precious Federal resources. These disproportionate punishments have
had a disparate impact on minority communities. This is unjust and runs contrary to our
fundamental principles of equal justice under law.”); 156 Cong. Rec. H6199 (daily ed. July 28,
2010) (statement of Rep. Lee) (“This disparity made no sense when it was initially enacted, and
makes absolutely no sense today. . . . The unwarranted sentencing disparity not only overstates the
relative harmfulness of the two forms of the drug and diverts federal resources from high-level
drug traffickers, but it also disproportionately affects the African-American community.”); id.
H6202 (statement of Rep. Lungren) (“We didn’t really have an evidentiary basis for [the 100-to-1
ratio], but that’s what we did . . . .”).
The Sentencing Commission also recognized that the 100-to-1 ratio was unjustified and
unjust. “The 100-to-1 drug quantity ratio was established based on a number of beliefs about the
relative harmfulness of the two drugs and the relative prevalence of certain harmful conduct
associated with their use and distribution that more recent research and data no longer support.”
U.S. Sent’g Comm’n, Report to Congress: Cocaine and Federal Sentencing Policy 91 (2002). In
addition, the 100-to-1 ratio “fosters disrespect for and lack of confidence in the criminal justice
system” because of a “widely-held perception” that it “promotes unwarranted disparity based on
race.” 2002 Crack Report at 103.
The Department of Justice, too, recognized that the law lacked rational basis and had a
racially disparate impact. See Restoring Fairness to Federal Sentencing: Addressing the Crack
Powder Disparity: Hearing Before the S. Comm. on the Judiciary, 111th Cong. 5 (2009)
(statement of Assistant Attorney General Lanny Breuer) [“Statement of AG Breuer”] (endorsing
the Commission’s evidence that the 100:1 crack to powder disparity “is difficult to justify based
on the facts and science” and advocating its elimination).
7

United States v. Holloway, 68 F.Supp.3d 310, 317 (E.D.N.Y. 2014) (stating that multiple decade
sentences for nonviolent drug trafficking are “grotesquely severe”).
But in the particular circumstances of Charles’s case there is more to consider. It is crystal
clear that society does not need another pound of Charles’s flesh to set the moral balance straight.
If at his sentencing hearing in 1996 his lawyer had merely uttered a pointless objection to be
brushed off as moot, Charles’s subsequent sentence reduction to 292 months would have survived,
as did Larry Turnley’s. The district judge’s assessment of his rehabilitation and character would
have fully justified sentencing Charles within the range authorized by Congress in the Fair
Sentencing Act and by the Sentencing Commission in its retroactive amendments to the drug
guidelines. Society’s interest in retribution cannot justify Charles’s being stuck with a 420-month
sentence if what separates him from beneficiaries of the amendment, e.g. Larry Turnley, is the
utterance of a pointless objection at a hearing 20 years ago.
2. Specific deterrence. Nothing in the last two decades remotely suggests Charles
needs to be deterred from crime. Charles never had a single disciplinary write-up in over twenty
years in prison. Taking classes and working, he was a model inmate. On supervised release, his
record is immaculate. He works full time, does volunteer work to serve the poor, and is a shining
example of what a person can, despite felony convictions, make of his life.
3. General deterrence. “Under the theory of general deterrence, the government
essentially seeks to make an example of an offender through punishing him so that other potential
offenders are intimidated into refraining from committing the contemplated crime.” Slatten, 865
F.3d at 819 (quoting 1 Wharton’s Criminal Law § 3 (15th Ed. Sept. 2016). There is no reason to
think that, for example, a 35-year sentence would deter a street-level drug dealer where a 20-year
sentence would fail to. United States v. Bannister, 786 F. Supp. 2d 617, 668 (E.D.N.Y. 2011).
4. Rehabiliation. It is obvious that another decade in prison won’t serve to

rehabilitate Charles because he is already rehabilitated.
In sum, it seems clear that the government would be unable to identify any penological
purpose that would be served by sending Charles back to prison for a decade. The government’s
best rejoinder would be to invoke the system’s abstract interest in finality: Charles’s 420-month
sentence was valid when it became final; its subsequent reduction was unauthorized by law; and
so the original sentence should be reinstated. In other words, Charles should not be able to get a
lesser sentence by virtue of having won and then lost a sentence-reduction motion.
Finality, however, is not a “penological justification.” Graham, 560 U.S. at 71. Nor is it
remotely fair to put that interest above all others in the “particular circumstances of this case” and
other fairness considerations. Id. at 59. Charles’s original sentence was imposed in violation of
the two distinct constitutional principles of Apprendi and Booker that the courts simply hadn’t
quite recognized yet in 1996; letting those violations go unaddressed is not fair. Moreover,
society’s softened view of crack-cocaine offenses is precisely the kind of development that is
supposed to give prisoners a chance at a retrospective sentence reduction under § 3582(c)(2); his
denial of that chance is not fair. It is cruel to send a thoroughly virtuous person back to prison for
a decade simply to satisfy an abstract interest in finality, and this Court should refrain from doing
so.
IV. Charles is a strong candidate for Holloway relief.
In 1995, Francois Holloway, then age 38, was convicted of carjacking three cars at
gunpoint. Holloway, 68 F.Supp.3d at 312. He was sentenced to a mandatory 57 years in prison
by Judge Gleeson of the Eastern District of New York based on the requirement that convictions
under 18 U.S.C. § 924(c) must be stacked and served consecutively. Id. at 312-13. Eighteen
years later, Judge Gleeson, who was previously a federal prosecutor, asked then-U.S. Attorney
Loretta Lynch to agree to an order vacating two or more of Holloway’s convictions, thereby

making him immediately eligible for release. Id. at 314. As Judge Gleeson noted, “[Holloway]
would likely have fared better had he committed murder. The average sentence in federal court
for murder in fiscal year 2013 was 268 months; the median was 240 months. If Holloway had
gotten 268 months, he’d already be out of prison.” Id. at 313. Additionally, Judge Gleeson
observed that Holloway had bettered himself in prison and had only incurred five minor
disciplinary infractions during his almost twenty years in prison. Id. at 314.
U.S. Attorney Lynch initially rejected Judge Gleeson’s request on the basis that Holloway
should apply for a commutation of his sentence. Holloway, 68 F.Supp.3d at 314. After a new
clemency initiative made clear that it was unlikely Holloway would receive a commutation
because of the violent nature of his crimes, Judge Gleeson asked U.S. Attorney Lynch to
reconsider his request. Id. Upon reconsideration, U.S. Attorney Lynch agreed, by declining to
raise procedural defenses, to a dismissal of two counts of Holloway’s conviction, ultimately
resulting in Holloway’s release from prison. Id. at 315. Judge Gleeson stated the following in his
decision granting the relief:
This is a significant case, and not just for Francois Holloway. It demonstrates the
difference between a Department of Prosecutions and a Department of Justice. It shows
how the Department of Justice, as the government’s representative in every federal
criminal case, has the power to walk into courtrooms and ask judges to remedy injustices.
The use of this power poses no threat to the rule of finality, which serves important
purposes in our system of justice. There are no floodgates to worry about; the authority
exercised in this case will be used only as often as the Department of Justice itself chooses
to exercise it, which will no doubt be sparingly. But the misuse of prosecutorial power
over the past 25 years has resulted in a significant number of federal inmates who are
serving grotesquely severe sentences, including many serving multiple decades and even
life without parole for narcotics offenses that involved no physical injury to others. Even
seasoned federal prosecutors will agree that many of those sentences were (and remain)
unjustly severe.
The United States Attorney has shown here that justice is possible in those cases. A
prosecutor who says nothing can be done about an unjust sentence because all appeals and
collateral challenges have been exhausted is actually choosing to do nothing about the
unjust sentence. Some will make a different choice, as Ms. Lynch did here.
10

Id. at 316-17.
Matthew Charles is now 51 years old. He is a perfectly kind and responsible person, and
he is a blessing for the people who live and work with him. There is nothing to be gained by
sending him back to prison. He poses no meaningful risk to public safety. Spending hundreds of
thousands of dollars to reincarcerate him is a waste of resources, both human and financial, and
would serve no just purpose. Accordingly, Charles respectfully requests that the Court make an
inquiry with the government regarding Holloway relief and that it ultimately impose a sentence of
292 months.
Conclusion
For the reasons stated, Matthew Charles requests a sentence of 292 months.
Respectfully submitted,
/s/ Mariah A. Wooten

MARIAH A. WOOTEN (BPR# 006259)
First Assistant Federal Public Defender
MICHAEL C. HOLLEY (BPR# 021885)
Assistant Federal Public Defender
810 Broadway, Suite 200
Nashville, TN 37203
615-736-5047
E-mail: mariah_wooten@fd.org
E-mail: Michael_holley@fd.org
Attorneys for Matthew Charles
CERTIFICATE OF SERVICE
I hereby certify that on December 7, 2017, I electronically filed the foregoing Defendant’s
Sentencing Memorandum and, In the Alternative, Motion to Initiate Holloway Relief with the
U.S. District Court Clerk by using the CM/ECF system, which will send a Notice of Electronic
Filing to the following: Cecil VanDevender, Assistant United States Attorney, 110 Ninth Avenue
South, Suite A-961, Nashville, Tennessee 37203.
s/ Michael C. Holley
MICHAEL C. HOLLEY
11

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UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF TENNESSEE

UNITED STATES OF AMERICA )

DEFENDANT’S SENTENCING MEMORANDUM

United States v. Holloway, 68 F.Supp.3d 310 (E.D.N.Y. 2014).

Case 3:96-cr-00051 Document 220 Filed 12/07/17 Page 1 of 11 PageID #: 553

2. Had only a few immaterial words been uttered at Charles’s sentencing

Case 3:96-cr-00051 Document 220 Filed 12/07/17 Page 2 of 11 PageID #: 554

of him returning to prison for at least nine more years.

I. The Sixth Circuit’s instructions do not preclude a resentencing under § 3553.

jurisdiction to reconsider and ultimately reimpose a modified term of imprisonment.”) The

Case 3:96-cr-00051 Document 220 Filed 12/07/17 Page 3 of 11 PageID #: 555

See Greenlaw, 554 U.S. at 249.

to the further sentencing proceedings that had to take place.

powers to reinstate a former sentence outside the § 3553-compliant resentencing procedure

Case 3:96-cr-00051 Document 220 Filed 12/07/17 Page 4 of 11 PageID #: 556

resentencing procedure in the first instance.

remand should be, in effect, unmistakable.” Id.

mandated “further sentencing proceedings” to this Court.

II. At a resentencing under § 3553, it would be illegal to impose a 420-month

Case 3:96-cr-00051 Document 220 Filed 12/07/17 Page 5 of 11 PageID #: 557

Case 3:96-cr-00051 Document 220 Filed 12/07/17 Page 6 of 11 PageID #: 558

Case 3:96-cr-00051 Document 220 Filed 12/07/17 Page 7 of 11 PageID #: 559

sentences for nonviolent drug trafficking are “grotesquely severe”).

utterance of a pointless objection at a hearing 20 years ago.

3. General deterrence. “Under the theory of general deterrence, the government

4. Rehabiliation. It is obvious that another decade in prison won’t serve to

Case 3:96-cr-00051 Document 220 Filed 12/07/17 Page 8 of 11 PageID #: 560

IV. Charles is a strong candidate for Holloway relief.

gunpoint. Holloway, 68 F.Supp.3d at 312. He was sentenced to a mandatory 57 years in prison

Case 3:96-cr-00051 Document 220 Filed 12/07/17 Page 9 of 11 PageID #: 561

raise procedural defenses, to a dismissal of two counts of Holloway’s conviction, ultimately

decision granting the relief:

Case 3:96-cr-00051 Document 220 Filed 12/07/17 Page 10 of 11 PageID #: 562

/s/ Mariah A. Wooten

Attorneys for Matthew Charles

Case 3:96-cr-00051 Document 220 Filed 12/07/17 Page 11 of 11 PageID #: 563

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