United States v. Robert Preston Narramore

This appeal involves a 1992 Sentencing Guideline amendment that made it possible for a defendant to receive an additional reduction in the applicable base offense level for acceptance of responsibility. Section 3El.l(a) of the Guidelines allows for a two-level reduction “[i]f the defendant clearly demonstrates acceptance of responsibility for his offense.” In 1992, section (b) was added, which provides:

The defendant-appellant, Robert Narra-more, pleaded guilty to eleven counts in an indictment charging offenses related to his role in a conspiracy to manufacture and sell methamphetamine. He received a two-level downward adjustment pursuant to section (a), but he challenges on appeal the district court’s denial of his request for an additional one-level reduction under section (b).

Narramore argued to the district court that his plea of guilty was sufficiently timely to warrant the additional one-level adjustment under subsection (b)(2). The district court denied the reduction because Narra-more did not plead guilty until a week before the scheduled trial date, and after the government had begun seriously to prepare for trial.

The novel contention advanced by Narramore in this…