The Sixth Circuit Court of Appeals has upheld the sentencing of Tristan Murphy, who was convicted of conspiring to commit a Hobbs Act robbery. Murphy, who had previously pleaded guilty, was sentenced to 37 months in prison and a subsequent three-year term of supervised release. However, after violating the terms of his release, Murphy sought to reduce his sentence, claiming that a recent amendment to the sentencing guidelines should apply to his case. The court ruled against him, affirming the original sentence.
This ruling impacts Murphy directly, as he will continue to serve the sentence imposed by the district court. The decision also highlights the complexities of sentencing guidelines and the legal interpretations that can arise during supervised release violations.
Background
Tristan Murphy was part of a group that attempted to rob a jewelry store in Florida in June 2019. The robbery was thwarted by police before they could escape with stolen goods. In April 2021, he pleaded guilty to conspiracy to commit Hobbs Act robbery under 18 U.S.C. § 1951(a). During his initial sentencing, the court calculated Murphy's criminal history score based on two prior convictions, which placed him in criminal history category III. This score was increased due to Murphy being on probation at the time of the robbery attempt, leading to a sentence of 37 months in prison followed by three years of supervised release.
Murphy's supervised release began in February 2022, but he violated its terms in June 2024 when he was found driving on a suspended license and in possession of firearms and marijuana. Following this violation, he was charged with three counts related to his supervised release. In a separate case, he pleaded guilty to being a felon in possession of a firearm in West Virginia and received an additional 35-month prison sentence.
The Ruling
During the hearing regarding Murphy's supervised release violations, the district court determined that Murphy's criminal history category remained at III, as it was at the time of his original sentencing. Murphy argued that a recent amendment to the United States Sentencing Guidelines, which took effect in November 2023, should have reduced his criminal history category to II. The amendment changed how points are assigned for individuals on probation at the time of their offenses.
However, the district court opted to follow the existing commentary in the guidelines, which stated that the criminal history category applicable during a supervised release sentence is the one used at the original sentencing. The court emphasized the importance of adhering to the Sentencing Commission's guidelines, stating, "I will follow the application note because that is the pronouncement of the Sentencing Commission about how these guidelines should be interpreted." Ultimately, the court sentenced Murphy to 18 months in prison for the supervised release violations, to run consecutively to his West Virginia sentence.
Impact
The Sixth Circuit's decision to affirm the district court's ruling means that Murphy will continue to serve his sentence without any reduction. This case illustrates the importance of the Sentencing Guidelines and how amendments can affect sentencing outcomes. It also emphasizes the court's reliance on established guidelines over more recent amendments when determining sentences for supervised release violations.
This ruling may set a precedent for future cases involving similar circumstances, particularly regarding how courts interpret and apply amendments to the Sentencing Guidelines. Defendants in similar situations may face challenges if they seek to benefit from new amendments that do not retroactively apply to their cases.
What's Next
Murphy has the option to appeal the decision, but the court's affirmation of the original sentencing may limit his chances for success. There are no related cases pending that would directly impact Murphy's situation.