United States v. Marvin Williams

── United States v. Marvin Williams ── Court: Court of Appeals for the Eighth Circuit Date: May 26, 2026 Category: General United States Court of Appeals For the Eighth Circuit ___________________________ No. 24-3119 ___________________________ United States of America Plaintiff - Appellee v. Marvin D. Williams Defendant - Appellant ____________ Appeal from United States District Court for the Eastern District of Missouri - St. Louis ____________ Submitted: January 12, 2026 Filed: May 26, 2026 [Published] ____________ Before SHEPHERD, KELLY, and STRAS, Circuit Judges. ____________ PER CURIAM. Marvin Williams pleaded guilty to drug and gun charges, and the district court1 imposed a 180-month sentence of imprisonment. Williams appeals his sentence, and we affirm. 1 The Honorable Matthew T. Schelp, United States District Judge for the Eastern District of Missouri.  I. In November 2022, law enforcement conducted two controlled buys. In the first, Williams sold 27.9 grams of a mixture containing methamphetamine to a confidential source. About a week later, he sold the confidential source 55.4 grams of the same. On November 21, 2022, officers executed a search warrant at Williams’s home where they seized 31.38 kilograms of actual methamphetamine, digital scales, drug packaging materials, a drug ledger, $42,530 in cash, and five firearms. On April 10, 2023, Williams pleaded guilty to four offenses: possession with intent to distribute actual methamphetamine, in violation of 21 U.S.C. §§ 841(a)(1) and (b)(1)(C) (Count 1); two counts of distribution of a mixture containing methamphetamine, in violation of 21 U.S.C. §§ 841(a)(1) and (b)(1)(C) (Counts 4 and 5); and one count of possession of a firearm after having been convicted of a felony, in violation of 18 U.S.C. § 922(g)(1) (Count 3).2 In the Plea Agreement, the parties agreed that Williams was responsible for more than 4.5 kilograms of actual methamphetamine, resulting in a base offense level 38. See USSG § 2D1.1(c)(1) (assigning base offense level 38 for 4.5 kilograms or more of actual methamphetamine). The parties also agreed a 2-level enhancement applied because Williams possessed a firearm, see USSG § 2D1.1(b)(1) (“If a dangerous weapon (including a firearm) was possessed, increase [the base offense level] by 2 levels.”), and that Williams qualified for a 3-level reduction for acceptance of responsibility, see USSG § 3E1.1. The Presentence Report adopted the parties’ calculations, resulting in a recommended sentencing range of 235–293 months. At sentencing, Williams objected to this range, arguing that the distinction in the Guidelines between actual methamphetamine and a mixture containing methamphetamine was “completely arbitrary.” Williams asked the district court to recalculate the sentencing range using a base offense level 36 for a mixture 2 The government agreed to dismiss Count 2 of the Superseding Indictment. -2- containing methamphetamine—and a range of 188–235 months—rather than a level 38 for actual methamphetamine. The district court overruled the objection, but varied downward and imposed concurrent sentences of 180 months and a 3-year term of supervised release. II. On appeal, Williams asserts the district court erred when it calculated his Guidelines range based on actual, rather than a mixture containing, methamphetamine. “Miscalculating the sentencing guidelines is a pro