United States v. Rick Kelley

Summary

Rick Kelley, having pleaded guilty to two drug conspiracy offenses and money laundering, challenged on appeal the district court's drug quantity determination and its denial of a mitigating role adjustment. The Eighth Circuit declined to decide whether the guideline calculations were erroneous, because the district court expressly stated it would have imposed the same 24-month sentence under 18 U.S.C. § 3553(a) regardless of the guideline calculations. The court held any guideline error was harmless and affirmed.