Argues for a variance.
Argues against relying on the career offender guidelines, citing criticism from courts and the Sentencing Commission’s recommendation that the career offender provision be limited to those with prior violent convictions. Argues, too, that the Guidelines for pure methamphetamine produce inequitable results, because they are out of date, failing to recognize that almost all the methamphetamine now distributed is of high quality. Contends defendant’s poor health and age support a below-guideline sentence.
Relies on defendant’s difficult childhood and his addiction to drugs. Criticizes the Guidelines for firearm possession.
Cites criticism of the production of child pornography guideline. Relies on recidivism statistics to show no need for a long sentence to protect the public. Brief reference to client’s youth.
Cites criticism of child pornography guideline and the collateral punishment that comes with being designated a sex offender.
Discusses defendant’s difficult upbringing and his success in overcoming it. Relies on letters of support written by family and friends. Uses reports of psychologists to demonstrate a below-average risk of recidivism. Cites criticism of the applicable guideline. Provides history of the ever-increasing penalties for the offense.