In a decision that underscores the importance of precise legal definitions, the U.S. Court of Appeals for the Sixth Circuit has overturned a 20-year supervised release sentence handed down to Rihanna Buddi.
The court ruled on Tuesday that the district judge not only used the wrong classification for her underlying crime but also appeared to misunderstand the federal sentencing guidelines.
The case, United States v. Buddi, centers on a woman who moved from Florida to Tennessee in 2023. While Buddi was a registered sex offender in Florida due to a 2017 conviction for lewd and lascivious battery, she failed to update her registration upon moving to the town of Bulls Gap.
She eventually pleaded guilty to violating the Sex Offender Registration and Notification Act (SORNA).
The “Tier” Trouble
The core of the legal dispute was how Buddi’s Florida conviction should be categorized under federal law. The government argued she was a “Tier II” offender, a label that carries harsher sentencing implications.
This classification was based on the idea that her Florida crime was “comparable” to the federal crime of “coercion and enticement.”
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However, the three-judge panel—consisting of Jane Branstetter Stranch, John Kenneth Bush, and Chad Andrew Readler—found a significant gap between the two laws. Florida’s law is essentially a strict-liability statute regarding age; it doesn’t matter if the offender knew the victim was a minor. Federal law, the court noted, requires “knowing” intent.
Writing for the court, Judge Stranch pointed out that “knowingly” in the federal statute applies to the victim’s age. Because the Florida law sweeps more broadly by not requiring that knowledge, it cannot be used to bump an offender into a higher tier. Consequently, the court ruled Buddi is a Tier I offender.
A Math Error at Sentencing?
Beyond the classification, the appellate court took issue with how the lower court arrived at a 20-year term of supervised release. The advisory guidelines suggested a flat five-year term. Yet, the district court imposed 20 years.
The Sixth Circuit noted that at the start of the sentencing hearing, the district judge described the “advisory guideline range” as “five years to life.” In reality, five years to life was the statutory range—the legal limits set by Congress—while the guidelines range was much narrower.
“It defies credulity to think that the court knowingly imposed a supervised release sentence fifteen years over the Guidelines range with no acknowledgement of or explanation for that decision,” Judge Stranch wrote.
The Road Ahead
Though Buddi has already finished her 24-month prison term, the ruling is far from moot. Because her supervised release is currently active, the appellate court’s decision to vacate that portion of her sentence means she will head back to the district court for a new sentencing hearing.
The court’s decision serves as a reminder to the legal community that even in cases involving sensitive subject matter, the “categorical approach” to law must be applied with clinical precision.
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