Sentencing based on uncharged conduct
Stephen Reed Pattison v. United States
In brief
- Where it stands
- Dismissed
Petition denied.
- What it’s about
- Stephen Pattison asked the Supreme Court to review his sentence, arguing that the district court more than doubled the agreed-upon Guidelines range and that courts disagree about what “similar” uncharged conduct means and whether the Guidelines’ examples are exclusive.
- Who it affects
- Pattison did not get Supreme Court review of his sentence, and the Court did not resolve the guideline questions he raised.
Summary: written with AI from the case record.
What it's about
The Court refused to hear the case (denied review), so it did not decide those issues.
Pattison said the district court more than doubled the sentencing range the parties had agreed on.
Pattison's petition focused on how a federal sentencing guideline treats uncharged prior conduct described as similar to a defendant's offense.
Question presented
In a criminal matter where the District Court more than doubled the agreed upon Guidelines range, whether this Court should resolve the Circuit split as to what “similar” uncharged prior conduct under U.S.S.G. §4A1.3(a)(2)(E) means and whether the carefully delineated §4A1.3(a)(2) list was meant to be an exclusive itemization of examples despite the use of the word, “may,” as these issues continue to impact defendants who were sentenced pursuant to this upward departure prior to the November 2025 amendments to the Sentencing Guidelines.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Brief added: Petition
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.