United States v. Willis — Fifth Circuit upheld the sentence and drug-quantity calculation

Case
United States of America v. Dewayne Deshae Willis
Court
U.S. Court of Appeals for the Fifth Circuit
Judge
Jones (Ronald Reagan, 1985); Ho (Donald Trump, 2017); Wilson (Donald J. Trump, 2020)
Date Decided
August 10, 2026
Docket No.
25-11061
Topics
Criminal Sentencing; Drug Quantity; Plain-Error Review
Source
Read the full opinion

Background

Dewayne Deshae Willis pleaded guilty to possession with intent to distribute a mixture or substance containing a detectable amount of cocaine. The U.S. District Court for the Northern District of Texas sentenced him to 136 months in prison.

On appeal, Willis challenged the quantity of drugs attributed to him in calculating his base offense level. He argued that statements from three confidential sources—identified as CS 2, CS 3, and CS 4—were unreliable and that the calculation based on CS 4’s statement was “patently incorrect.”

The Court’s Holding

The Fifth Circuit affirmed the sentence. Applying plain-error review, the court held that Willis had not shown reversible plain error in the district court’s drug-quantity calculation.

The per curiam, unpublished opinion did not separately analyze the challenged confidential-source statements or provide further reasoning concerning the calculation. It left the district court’s 136-month sentence intact.

Key Takeaways

  • A defendant challenging a sentencing drug-quantity calculation under plain-error review must establish reversible plain error.
  • Willis’s reliability objections to the confidential sources did not persuade the panel that this standard was met.
  • The Fifth Circuit affirmed the 136-month sentence in an unpublished, summary-calendar opinion.

Why It Matters

The decision illustrates the difficulty of overturning a drug-quantity finding under plain-error review. Even when a defendant attacks the reliability of confidential-source information used at sentencing, the appellate burden requires a showing of reversible plain error.

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