Defendant Sentenced to Law School

The books there were probably more interesting (image: Tobias Kleinlercher via Wikipedia, CC 3.0)

The ABA Journal reports that in August 2019, Chelsea Nichole Madill pleaded guilty to drug-trafficking charges that generally result in about five years in federal prison. But Madill got no jail time, just probation, and was fined just $100.

On the other hand, she was ordered to finish law school.

According to the criminal complaint, Madill was part of a drug-trafficking organization, which the complaint calls a “DTO” but I will call a “gang.” In March 2018, it alleges, she leased a warehouse in McAllen, Texas (just this side of the border) for her company, “Monsters Inc. Logistics.” Two months later, agents watching the warehouse saw Madill supervise the loading of a truck that was later found to contain almost 30 kilos of cocaine. Cellphone records allegedly showed that after the seizure, Madill called the gang’s leader in Mexico and then traveled there to meet him. She was later arrested in Florida, and was charged with cocaine possession and conspiracy with intent to distribute.

The government filed the complaint in January 2019, and Madill pleaded guilty to conspiracy in August of that year. But the court didn’t enter the judgment until January of this year. The court sentenced Madill to time served (five days), three years of probation, and the $100 fine. But under “Special Conditions of Supervision,” the judgment tells Madill that she “must continue to participate [in] and complete an educational program designed to receive a Doctor of Jurisprudence degree.” No further explanation.

Much of the docket is sealed, including a “motion for downward departure” from the sentencing guidelines and the “statement of reasons” filed with the final judgment. But it does show that after the 2019 plea agreement, the court repeatedly delayed sentencing. Based on my extensive knowledge of criminal procedure (gained almost entirely from watching Law & Order), I speculate that the investigation was ongoing and sentencing was delayed to ensure that the defendant did whatever she had promised to do.

Did that include going to law school? Well, the judgment requires the defendant to “continue” in a J.D. program, so that suggests it did. The Journal also found this message from the president of the Student Bar Association of Florida A&M University (mascot: the rattlesnake) welcoming the incoming class for the 2022–23 school year. The list of committee members at the end mentions a “Chelsea Madill” as the 2L SBA representative. If in fact this is the same person, then she would have started law school in the fall of 2021 and would not yet have completed it.

Comments on the report have ranged from outrage that a drug trafficker would get off so easily, and might even become a lawyer, to satisfaction that a defendant charged with a non-violent crime is getting a chance to turn her life around. Someone also speculated that the defendant may have promised to go to law school when seeking a lighter sentence, but might lose interest in actually becoming a Rattler for Justice (the SBA president’s term, not mine) once that was achieved. The judge’s order would, under that view, be intended to prevent any backsliding. As for whether the defendant might actually become a lawyer, there would still be the bar exam (which the order doesn’t require her to take), and even if she passed, there would also be the moral-character evaluation to worry about.

But as you know, being convicted of a felony does not necessarily disqualify a person from being a lawyer—although maybe some felonies really should. See, e.g., “Convicted Killer Headed Back to Law School” (Sept. 1, 2011) (discussing student who was out on parole despite having stabbed a guy 33 times). Conversely, by no means does passing the bar and a moral-character evaluation guarantee the resulting lawyer won’t be a crook, even if he or she has no past criminal record. See, e.g., “Disgraced Lawyer’s Crocodile Shoes Sold for $1062” (Sept. 20, 2022). Oh, no. Not at all. See, in fact, That Entire Category. The idea that it might is a real hoot. So let’s see what happens. You never know.