United States v. Stacy Owens -Middle District of Tennessee at Nashville
Split Score
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Case Summary
Disposition
Affirmed
The primary issue was whether Stacy Owens’s failure to self-surrender—charged as criminal contempt—should be treated as a felony or misdemeanor when calculating the Sentencing Guidelines range. The Sixth Circuit adopted a case-by-case, analogous-offense approach, deemed Owens’s contempt a felony under Guideline §2X5.1 by analogizing it to 18 U.S.C. §3146, and affirmed her 11-month consecutive sentence.
Circuit Split Identified
Legal Issue
Whether criminal contempt under 18 U.S.C. §401 must be automatically classified as a felony (Class A) for sentencing purposes or classified case-by-case based on the most analogous underlying offense.
Circuit Positions
Criminal contempt is automatically a Class A felony regardless of underlying conduct.
Criminal contempt is classified case-by-case by reference to the statutory maximum of the most analogous offense; it is a felony only when the analogous offense is a felony.
Conflict Summary
The First Circuit automatically treats all criminal contempt convictions as Class A felonies, while the Ninth and Eleventh Circuits (and now the Sixth) require a case-specific analysis that classifies contempt according to the statutory maximum of the most analogous underlying offense—sometimes resulting in misdemeanor or lower-class felony treatment.