Sentencing Memorandum — No. 4:23-cr-00692 (Dkt. 70, E.D. Mo.)

Summary

A four-page sentencing memorandum, Document 70, filed 07/08/25 by attorney Kenneth R. Schwartz for Terrell Williams in United States v. Williams, No. 4:23-CR00692 SEP, in the U.S. District Court for the Eastern District of Missouri. Williams pleaded guilty to one count of Animal Fighting under 7 U.S.C. Section 2156; the presentence report puts him at total offense level 13 and criminal history category II, a range of 15 to 21 months. The memorandum describes a 52-year-old lifelong resident of St. Louis introduced to dog fighting as a boy by an uncle in rural Tennessee, and devotes most of its length to the history of dog fighting in the American South, with a sociological study by Kalof and Taylor (2007). It notes that the plea agreement has both parties recommending 18 months and asks the court to impose that term.

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“Sentencing Memorandum — No. 4:23-cr-00692 (Dkt. 70, E.D. Mo.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/sentencing-memorandum-no-4-23-cr-00692-dkt-70-e-d-mo-13e0658522/, SHA-256 452b114c0ae3ca5470015fec7a9b653ef6bef30579be303ff8b6f62fcf8c61dc.

Full text

Case: 4:23-cr-00692-SEP Doc. #: 70 Filed: 07/08/25 Page: 1 of 4 PageID #: 158

IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION

UNITED STATES OF AMERICA, ) No. 4:23-CR00692 SEP
)
Plaintiff, )
)
vs. )
)
TERRELL WILLIAMS, )
)
Defendant. )

SENTENCING MEMORANDUM

Comes now Terrell Williams, by and through his attorney, and states to the Court

as follows:

1. The Defendant is scheduled for sentencing before this Honorable Court. The

applicable sentencing statute, 18 U.S.C. §3553(a), assigns to this court the duty to

impose a sentence that is sufficient, but not greater than necessary, to satisfy the

statutory purposes of sentencing.

2. The defendant pleaded guilty to one count of Animal Fighting, under 7 U.S.C.

Section 2156.

3. The pre-sentence investigation report prepared by the Department of

Probation sets forth a sentencing calculation which places the defendant, at a total

offense level of 13, and a criminal history category of II. This equation sets the

suggested range of punishment at 15 to 21 months.

4. Terrell Williams is a 52 year old lifelong resident of St. Louis, Missouri.

1
Case: 4:23-cr-00692-SEP Doc. #: 70 Filed: 07/08/25 Page: 2 of 4 PageID #: 159

Terrell was born into a family where his father wasn’t around much. His family all

came from Mississippi. African American people in the St. Louis, Missouri area largely

migrated her when they were freed from slavery. During his youth Terrell would be sent

back to family, that still resided in rural Tennessee, to visit for summers. He had an

uncle in Tennessee who introduced Terrell to dog fighting. Terrell was young and

impressionable. Dog fights in the south were attended by black and white people. To a

young boy it seemed ok; It was an activity that the grownups took part in. It was no

surprise that as Terrell grew older he continued to be interested in dog fighting. It

appears as though the majority of people in the St. Louis area engaged in dog fighting

are African American; this isn’t a coincidence.

A brief glance at the history of dog fighting sheds some light on how this practice

became part of the southern, African American, primarily rural, landscape.

Pitbulls made their way to America sometime around 1845 to 1860 where they

were included in the Military, especially during the Civil War, as infantry mascots and as

attack and search and rescue dogs on the front line.

Fighting dogs were introduced by the British into four colonial domains in

America, but were especially coveted in slave plantations in the south. The dogs, often

referred to as ‘catch dogs’ were relied upon to carry out tasks such as killing rats, help

hunt boar, protect the home and catch runaway slaves.

Following the Civil War and emancipation, African American men began to enter

the primarily white-only dog fighting fray. African American men at this time would

operate dogfighting in black only settings. They had small fight purses, informal fights,

and the fights often took place in alleyways, backstreets, or out of the way areas, similar

to underground dogfighting in modern times.

https://www.researchgate.net/publication/284170655_Pit_bulls_slavery_and_whit

eness_in_the_mid-_to_late-nineteenth-century_US

Dog fighting has been studied by many sociologists. In one study
Case: 4:23-cr-00692-SEP Doc. #: 70 Filed: 07/08/25 Page: 3 of 4 PageID #: 160

“ninth-graders they interviewed in a secondary school in Pontiac, Michigan,
admitted that they had attended dogfights. Most of them stated that there was
nothing wrong with those events. This led the authors to conclude that those
children were desensitized to violence to such a high degree that they did not
perceive dogfights as cruel, immoral acts. There is also a risk that exposure of
young people to these organized acts of animal abuse may lead to later
development of behavioral traits that include animal abuse as well as bullying
and delinquency”
Kalof, L., & Taylor, C. (2007). The Discourse of Dog Fighting. Humanity & Society, 31(4), 319-
333. https://doi.org/10.1177/016059760703100403 (Original work published 2007)

Terrell works and has a wonderful wife and family. He got into some trouble while

he was younger. He served a 60 month sentence for a drug violation in 2007, when he

was 34 years old. He has consistently worked since being placed on supervised

release. He is now employed in the towing industry. He has been in the towing business

for a few years, including making an upward move to another company. While Terrell

managed to get most criminal activity out of his system the dog fighting remained. The

sociological study cited above may have some relevance. Terrell knew that the activity

was illegal, but somehow, he was desensitized to it. His attitude after being charged in

this case has been one of complete ownership and responsibility for his conduct. He

has completely removed dog fighting and the people he knew in dog fighting from his

life. He is looking forward to serving his sentence and paying his debt to society. He

takes responsibility for his actions….unconditionally. His absence will be a hardship to

his family. He wants to do his time, get out, and get back to supporting his family.

The government and Terrell entered into a plea agreement wherein the parties

would both recommend a sentence of 18 months imprisonment. It is Defense Counsel’s

position that a sentence of 18 months will satisfy the requirements of the sentencing

law. It’s unlikely that the criminal justice system will ever see Terrell again.

WHEREFORE, Terrell Williams respectfully requests that the Court, consistent

with the aforementioned law, sentence the defendant to a term of imprisonment of 18

3
Case: 4:23-cr-00692-SEP Doc. #: 70 Filed: 07/08/25 Page: 4 of 4 PageID #: 161

months, and any other relief the Court deems appropriate, under the circumstances for

the following reasons, counsel believes that such a sentence is sufficient, but not

greater than necessary, to satisfy the statutory purposes of sentencing.

BY s/ Kenneth R. Schwartz
KENNETH R. SCHWARTZ 44528 MO
Attorney for Defendant
222 South Meramec Ave, Suite 203
Clayton, Missouri 63105
(3l4) 863-4654
(314) 862-4357 – fax
kenneth@kennethrschwartz.com

PROOF OF SERVICE

The undersigned certifies that the above was electronically pursuant to the ECF
rules on this 8th day of July 2025.

s/ Kenneth R. Schwartz

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