## Facts

- Kailab David Hendrickson had a long history of methamphetamine use beginning in early adolescence, followed by addiction-associated instability and criminal conduct.
- In August 2013, Hendrickson burglarized a home and stole approximately 15 firearms (including rifles, shotguns, and a pistol); the firearms were later recovered.
- He was federally charged with possessing stolen firearms in violation of 18 U.S.C. § 922(j).
- Hendrickson pleaded guilty on February 4, 2014.
- The advisory Sentencing Guidelines range was calculated at 37–46 months’ imprisonment.
- The court issued a written sentencing opinion explaining its reasons under 18 U.S.C. § 3553(c), with substantial discussion of addiction and sentencing purposes.

## Issues

1. Whether Hendrickson’s severe methamphetamine addiction and related personal history warranted a downward variance from the advisory Guidelines range under 18 U.S.C. § 3553(a).
2. Whether, and to what extent, a sentencing court may treat severe addiction as a mitigating factor affecting culpability and the choice of a sentence “sufficient, but not greater than necessary” under § 3553(a).

## Decision

- The court imposed a below-Guidelines sentence, granting a downward variance from the advisory 37–46 month range.
- The court treated the Guidelines as advisory and applied the post-*Booker*/*Gall* framework: calculate the range, then impose an individualized sentence under § 3553(a) with an adequate explanation.
- The court found the firearm offense serious and potentially dangerous, supporting meaningful punishment, deterrence, and protection of the public.
- The court also found Hendrickson’s addiction was strongly connected to his criminal conduct and supported mitigation when weighing his “history and characteristics.”
- The court emphasized the statutory need to provide effective treatment and considered a sentence structure that better supported rehabilitation and reduced recidivism risk than a longer, purely punitive prison term.

## Legal Principles

- After *Booker* and *Gall*, a district court may impose a non-Guidelines sentence if it gives a case-specific explanation grounded in the § 3553(a) factors.
- Severe substance addiction may be considered under § 3553(a)(1) as part of the defendant’s history and characteristics, including as a mitigating factor when supported by the record.
- A sentencing court may weigh addiction-related impairments to impulse control and decision-making as relevant to relative culpability, without treating addiction as a complete excuse or as legal insanity.
- In selecting a sentence, courts must consider punishment, deterrence, protection of the public, and the need for effective medical or correctional treatment, and must impose a term that is “sufficient, but not greater than necessary.”
- Where the Guidelines do not fully account for individualized circumstances tied to addiction, a downward variance may be justified if consistent with § 3553(a) and explained under § 3553(c).

## Conclusion

The court imposed a below-Guidelines sentence for possessing stolen firearms, reasoning that Hendrickson’s severe methamphetamine addiction and its strong connection to his offense conduct materially affected the § 3553(a) analysis and supported a treatment-oriented downward variance consistent with the parsimony requirement.


United States v. Hendrickson, 25 F. Supp. 3d 1166 (N.D. Iowa 2014)