United States v. Jaylen Simpson

── United States v. Jaylen Simpson ── Court: Court of Appeals for the Sixth Circuit Date: April 27, 2026 Category: General RECOMMENDED FOR PUBLICATION Pursuant to Sixth Circuit I.O.P. 32.1(b) File Name: 26a0123p.06 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT ┐ UNITED STATES OF AMERICA, │ Plaintiff-Appellee, │ > No. 25-5729 │ v. │ │ JAYLEN SIMPSON, │ Defendant-Appellant. │ ┘ Appeal from the United States District Court for the Western District of Tennessee at Memphis. No. 2:24-cr-20218-1—Jon Phipps McCalla, District Judge. Decided and Filed: April 27, 2026 Before: STRANCH, BLOOMEKATZ, and HERMANDORFER, Circuit Judges. _________________ COUNSEL ON BRIEF: Needum L. Germany, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Memphis, Tennessee, for Appellant. Ashleigh Atasoy, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee. _________________ OPINION _________________ JANE B. STRANCH, Circuit Judge. Jaylen Simpson was convicted of carjacking resulting in serious bodily injury, as well as using, carrying, and discharging a firearm during the carjacking. During jury selection, Simpson pleaded guilty. He argues on appeal that the district court erred by declining to apply a two-level reduction for acceptance of responsibility and, separately, by giving excessive weight to the nature and circumstances of the offense at sentencing. Finding these arguments unpersuasive, we AFFIRM.  No. 25-5729 United States v. Simpson Page 2 I. BACKGROUND The details of Simpson’s offense conduct are undisputed. On May 16, 2024, Simpson entered the backyard of Anthony Crumpton’s house and hid behind a storage shed. Several minutes later, when Crumpton walked out of his house into the backyard, Simpson shot him in the abdomen with a 9mm pistol. Simpson then took Crumpton’s keys and drove away with his 2017 Kia Cadenza. He was apprehended several hours later by the Memphis Police Department after fleeing in the vehicle and then on foot. Later that day, Simpson was transported to the Violent Crimes Unit, where he waived his Miranda rights and agreed to speak with investigators. When asked whether the shooting was intentional or accidental, he replied, “[t]he second one I guess.” Crumpton was hospitalized for five weeks, during which he endured five surgeries, and completed physical therapy thereafter. Despite these medical efforts, which included multiple skin grafts, Crumpton was left permanently injured and unable to work. As of Simpson’s sentencing in July 2025, Crumpton continued to experience severe swelling and difficulties due to a large mass on his abdomen resulting from the shooting. A grand jury indicted Simpson on two counts: (1) carjacking resulting in serious bodily injury, in violation of 18 U.S.C. § 2119(2); and (2) knowingly using, carrying, and discharging a firearm during and in relation to a crime of violence, in violation of 18 U.S.C. § 924(c)(1)(A)(iii). Simpson pleaded guilty to these charges during jury selection. The Pr