United States v. Phillips

── United States v. Phillips ── Court: Court of Appeals for the Fifth Circuit Date: May 28, 2026 Category: Direct Criminal Case: 25-30067 Document: 71-1 Page: 1 Date Filed: 05/28/2026 United States Court of Appeals for the Fifth Circuit ____________ United States Court of Appeals Fifth Circuit FILED No. 25-30067 May 28, 2026 ____________ Lyle W. Cayce United States of America, Clerk Plaintiff—Appellee, versus James Troy Phillips, Defendant—Appellant. ______________________________ Appeal from the United States District Court for the Western District of Louisiana USDC No. 5:23-CR-214-10 ______________________________ Before King, Higginson, and Wilson, Circuit Judges. Cory T. Wilson, Circuit Judge: James Troy Phillips led police officers on a high-speed car chase in order to evade law enforcement because he had a large quantity of marijuana in his car. After he was caught, he pled guilty to marijuana charges. At sentencing, Phillips argued that the district court should disregard the statutory minimum because he met the requirements for the sentencing safety valve. In relevant part, safety valve relief is available only if the defendant did not “use violence or credible threats of violence or possess a firearm or other dangerous weapon . . . in connection with the offense.” 18 U.S.C. § 3553(f)(2). The district court denied safety valve relief but did not Case: 25-30067 Document: 71-1 Page: 2 Date Filed: 05/28/2026 No. 25-30067 initially articulate the basis for the court’s denial. After we ordered a limited remand for the district court to provide its reasoning, that court explained that it denied relief, inter alia, because Phillips’s high-speed car chase constituted the use of violence within the purview of § 3553(f)(2). We affirm. I. FBI agents came to suspect James Phillips’s marijuana-trafficking activities, so the agents had local law enforcement officers conduct a traffic stop of Phillips. Instead of complying with the stop, Phillips led the officers on a car chase that reached speeds of over 135 miles per hour. During the chase, he struck a vehicle and, at least for a time, evaded law enforcement. But Phillips’s escape to freedom was short-lived. After his eventual arrest and indictment, Phillips pled guilty to conspiracy to distribute and possess with intent to distribute marijuana in violation of 21 U.S.C. §§ 841(a)(1), 846. The presentence report calculated that Phillips’s guidelines imprisonment range was 51 to 63 months. Because his conviction carried a five-year mandatory minimum, the range’s floor was adjusted upward to 60 months. Id. § 841(b)(1)(B)(vii). In his sentencing memorandum, Phillips argued that the district court should disregard the mandatory minimum because he met the five requirements of the sentencing safety valve. See 18 U.S.C. § 3553(f). Under the safety valve, the district court “shall impose” a sentence “without regard to any statutory minimum sentence” if: (1) the defendant does not have— (A) more than 4 criminal history points . . . ; (B) a prior 3-point offense . . . ; and (C) a prior 2-point violent offense . . . ; 2 Case: 25-30067 Document: 71-1 Page: 3 Date Filed: 05/28/2026 No. 25-30067