Intrinsically Violent Kidnapping and Statutory Minimum Sentencing: A New Precedent from United States v. Lamar E. Sanders

Introduction

United States v. Lamar E. Sanders is a significant case rendered by the United States Court of Appeals for the Seventh Circuit on March 17, 2025. The case involves Lamar Sanders, who was convicted of kidnapping two victims—including a ten-year-old child—and extortion. The controversy at the heart of the case revolved around the appropriate statutory minimum sentence to be applied in a kidnapping involving a minor and whether the act itself qualifies as an intrinsically violent crime under federal law.

The parties include the United States of America as the Plaintiff-Appellee and Lamar E. Sanders as the Defendant-Appellant. Sanders’s argument for compassionate release based on recent changes in case law—particularly those addressing what constitutes a “crime of violence”—was central to his motion, which ultimately was denied by both the district court and the appellate court.

Summary of the Judgment

In this decision, the Seventh Circuit affirmed the district court’s denial of Sanders's motion for compassionate release. Sanders had been sentenced to 300 months in prison for the kidnapping offense under 18 U.S.C. § 3559(f)(2), which imposes a statutory minimum sentence for kidnappings involving a minor considered a violent crime. Despite Sanders’s contention that the crime did not meet the violent requirement—as suggested by the reading of recent case law— the district court concluded that the act of kidnapping a minor is intrinsically violent, thus justifying the 300-month statutory minimum sentence.

Additionally, Sanders argued that a disparity of five years between his current sentence and the alternative minimum under § 1201 (240 months) was “gross” enough to warrant compassionate release. However, both the district court and the appellate court found that the 5-year difference, in light of the full array of factors—including Sanders’s criminal history and relevant sentencing guidelines—did not constitute a gross disparity.

Analysis

Precedents Cited

The judgment referenced several key precedents that influenced the court’s decision:

Alleyne v. United States, 570 U.S. 99 (2013): This case established that any fact that increases a statutory minimum sentence must be determined by a jury. Sanders relied on this precedent to argue that his jury did not find the victim’s age to be a factor, thereby questioning the applicability of the heightened sentencing provision.
United States v. Jenkins, 849 F.3d 390 (7th Cir. 2017) and Sessions v. Dimaya, 584 U.S. 148 (2018): These cases contributed to the argument that federal kidnapping might not always qualify as a “crime of violence.” By suggesting that the statutory framework was misapplied, Sanders contended that a lower statutory minimum should apply.
United States v. Jackson, 932 F.3d 556 (7th Cir. 2019): This decision reaffirmed the interpretation given in Jenkins, providing further context on the statutory definitions of violence in kidnapping cases.
Bufkin v. Collins, No. 23-713 (U.S. Mar. 5, 2025): This more recent decision underscored the deference given to fact-intensive inquiries under the abuse-of-discretion standard when assessing whether a sentence disparity is “gross.”

The interplay of these precedents demonstrates the court’s careful balancing act of adhering to established statutory interpretation while considering the implications of new case law in similar contexts.

Legal Reasoning

The court’s reasoning rested on several pivotal points. First, the judgment recognized that the statutory framework under 18 U.S.C. § 3559(f)(2) treats the kidnapping of a minor as inherently violent, regardless of subsequent arguments over the presence of force. The court noted that Sanders’s factual record—a ten-year-old victim and a kidnapping committed at gunpoint—unequivocally validated the designation of the crime as violent.

Secondly, in addressing Sanders’s argument regarding the “gross disparity” between the 300-month sentence and the 240-month alternative, the court emphasized the individualized assessment required under 18 U.S.C. § 3553(a). Sanders’s extensive criminal history and the severity of the offenses were weighed alongside the nominal numerical difference. The court concluded that a five-year difference did not rise to the level of “gross disparity” that would justify a compassionate release.

Finally, the court acknowledged the evolving case law but reaffirmed that, in the present case, the established statutory minimum for child kidnapping remained applicable. The decision balanced statutory interpretation with the discretion afforded to sentencing judges, thereby leaving little room for reducing Sanders’s sentence under the claimed post-verdict changes in law.

Impact

This judgment is poised to influence future cases in several ways. First, by upholding the inherent classification of kidnapping a minor as a violent crime, courts may continue to apply stringent statutory minimum sentences in similar cases. The decision reinforces the principle that statutory language regarding "crimes of violence" is to be interpreted in light of the gravity inherent in crimes against minors.

Furthermore, the ruling on the “gross disparity” argument underscores the courts' deference to district courts’ individualized sentencing determinations. Future motions for compassionate release that hinge on minor differences between the actual and minimum sentences may face considerable hurdles if the underlying facts, particularly an offender’s criminal history, support a harsh sentence.

Complex Concepts Simplified

1. Intrinsically Violent Crime: In this context, the court treats any kidnapping involving a minor as automatically falling under the “violent” category, regardless of the presence of physical force beyond the fundamental act of kidnapping.

2. Statutory Minimum Sentence: This is the minimum number of months a defendant must be incarcerated as set by statute. In Sanders’s case, two statutory minimums were at issue: 300 months for a violent kidnapping (under § 3559(f)(2)) and 240 months under an alternative provision (under § 1201(g)); the court upheld the application of the higher threshold.

3. Gross Disparity: The term refers to a significant and unjustified difference between the sentence already imposed and the sentence that might be imposed in light of new law or evidence. Here, the court did not view a five-year difference as significant enough to trigger re-sentencing.

Conclusion

The decision in United States v. Lamar E. Sanders affirms the established precedent that kidnapping a minor is intrinsically violent, thereby justifying the application of the 300-month statutory minimum sentence. Despite arguments invoking recent case law and claiming a significant sentencing disparity, the courts remained committed to applying the existing statutory framework and deference in individualized sentencing assessments.

This ruling underscores the judiciary’s reliance on precedent and statutory mandates in sentencing determinations, particularly in crimes involving vulnerable victims such as children. It also highlights the challenges in seeking compassionate release based on minor variances between imposed and alternative statutory minimum sentences, setting a clear and structured path for future disputes in similar legal contexts.