United States v. Pankow

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Pankow started selling methamphetamine for a friend in 2015. After their supplier was incarcerated, Pankow’s friend drove to Minnesota to buy the methamphetamine. Pankow started helping her friend sell it out of their house and keeping a drug ledger. Pankow and the friend were returning from Minnesota with a purchase of methamphetamine when Wisconsin police stopped them for speeding. A K9 unit alerted to drugs in the car. Pankow had six outstanding arrest warrants. Officers searched the car and seized methamphetamine, marijuana, a drug ledger, and a large amount of cash. Pankow pleaded guilty to conspiring to distribute methamphetamine, 21 U.S.C. 846, 841(a)(1). The presentence report calculated a guidelines range of 108-135 months in prison. The parties agreed that the government would move under U.S.S.G. 5K1.1 for a sentence reflecting substantial assistance. The government filed its motion without a specific recommendation about the sentence, emphasizing the need for relative parity with the sentences it requested for other conspiracy members. Pankow argued that mitigating factors, including her vulnerability to men, warranted a lower sentence. The Seventh Circuit affirmed Pankow’s 84-month sentence. The court was not required specify to how much it “departed” from the guidelines range for Pankow’s substantial assistance and adequately considered the 18 U.S.C. 3553(a) factors, detailing Pankow’s characteristics and explaining that she deserved a lower sentence than the 120-month floor advocated by the government. View "United States v. Pankow" on Justia Law