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UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF OHIO

WESTERN DIVISION AT DAYTON

UNITED STATES OF AMERICA,

Plaintiff,

vs.

JORDAN B. SMITH, 

Defendant.

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Case No.: 3:17 CR 183(2)

UNITED STATES’ SENTENCING 

MEMORANDUM

 

Now comes the United States, by and through the undersigned Assistant United States 

Attorney, and respectfully provides the following sentencing memorandum.

Respectfully submitted,

BENJAMIN C. GLASSMAN

UNITED STATES ATTORNEY

s/Andrew J. Hunt

Andrew J. Hunt (0073698)

Assistant United States Attorney

200 West Second Street, Suite 600

Dayton, OH 45402

(937) 225-2910

Fax: (937) 225-2564

Andrew.Hunt@usdoj.gov

Case: 3:17-cr-00183-WHR Doc #: 151 Filed: 05/03/19 Page: 1 of 4 PAGEID #: 933
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MEMORANDUM

On or about June 15, 2017, Defendant Jordan Smith (“Smith”) transported money from 

the Dayton area to the Northern District of Illinois, and exchanged it there for approximately 5 

kilograms of cocaine. (R. 114, Plea Agreement, PAGEID# 808). On November 8, 2018, Smith

entered a guilty plea to Count Two of the Superseding Indictment, namely “Interstate travel in 

furtherance of an unlawful activity,” in violation of 18 U.S.C. § 1952. The statutory penalties 

include up to 5 years in prison. 

In crafting a sentence pursuant to 18 U.S.C. § 3553(a), the Court takes into account: 1) 

the nature and circumstances of the offense, and history and characteristics of the defendant, 2) 

the need to reflect the seriousness of the offense, to promote respect for the law, and provide just 

punishment for the offense, 3) the need to adequately deter criminal behavior, 4) the need to 

protect the public from future crimes of defendant, 5) providing rehabilitative services to 

defendant, 6) the kinds of sentences available, 7) the kinds of sentence and sentencing range 

established by the Sentencing Guidelines for the offense (and any pertinent policy statements), 8) 

restitution needs, and 9) the need to avoid unwarranted disparities among similarly situated 

defendants. The Court may place greater weight upon certain factors as opposed to others.

United States v. Zobel, 696 F.3d 558, 571 (6th Cir. 2012). 

Reviewing the Presentence Report, it is apparent that Smith’s adolescence was chaotic 

and – as evidenced by her present bond violations – she struggles with substance abuse and 

compliance with court directives. The United States also believes that Smith is the least culpable 

of the offenders charged in this scheme, as she was a courier. 

That said, she participated in a significant criminal violation involving the delivery of 

Case: 3:17-cr-00183-WHR Doc #: 151 Filed: 05/03/19 Page: 2 of 4 PAGEID #: 934
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several kilograms of cocaine, and her performance on bond has been extremely poor. Just 

punishment, promoting respect for the law, deterrence, and the seriousness of the offense require 

some period of incarceration. Nonetheless, the United States does not object to a downward 

variance from the applicable guideline range based on the above facts and in part the arguments 

raised by Smith in her sentencing memorandum.

CONCLUSION

In summary, the United States believes a prison term less than the applicable guideline 

range would be sufficient, but not more than necessary to address the 18 U.S.C. § 3553(a) 

factors.

Respectfully submitted,

BENJAMIN C. GLASSMAN

UNITED STATES ATTORNEY

s/Andrew J. Hunt

Andrew J. Hunt (0073698)

Assistant United States Attorney

200 West Second Street, Suite 600

Dayton, OH 45402

(937) 225-2910

Fax: (937) 225-2564

Andrew.Hunt@usdoj.gov

Case: 3:17-cr-00183-WHR Doc #: 151 Filed: 05/03/19 Page: 3 of 4 PAGEID #: 935
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CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing was served May 3, 2019, upon Mr. Nathan 

Stuckey, Esq., via CM/ECF electronic filing.

s/ Andrew J. Hunt

Andrew J. Hunt (007368)

Assistant United States Attorney

Case: 3:17-cr-00183-WHR Doc #: 151 Filed: 05/03/19 Page: 4 of 4 PAGEID #: 936