YOUNGSTOWN, Ohio (WKBN) — The attorney for a man accused of assaulting a U.S. Marshal before falling off a Niles motel balcony told a federal judge in a sentencing memorandum his client is far from a criminal mastermind.

In fact, wrote defense attorney Lawrence L. Delino Jr., his client, Montrell Holmes, 25, of Connecticut, “is more a caricature of a criminal than a successful one.”

Holmes pleaded guilty Jan. 11 to a charge of assaulting, resisting or impeding an officer. The charges stem from an Oct. 25 incident when members of the U.S. Marshals Northern Ohio Fugitive Task Force tracked Holmes to a Niles hotel.

Holmes is expected to be sentenced Friday by U.S. Judge Pamela A. Barker.

Holmes had an outstanding warrant out of Boardman where investigators there say he was one of several people involved in the theft of multiple vehicles, taking off from police and intentionally hitting a police cruiser.

Marshals surrounded the hotel and learned that Holmes was on a balcony. Marshals had to kick the door in and when they got inside, Holmes tried to run away. A marshal fired his stun weapon at Holmes, but the darts missed him, the affidavit in his criminal complaint said.

Marshals tried to physically stop Holmes from jumping off the balcony, but he ignored several commands until a railing gave way, and Holmes and a marshal fell to the ground, the affidavit said.

Both Holmes and the marshal were treated for injuries. Delino wrote that from the nature of his client’s injuries, “he is probably safer today than he would be on the street.”

While not making light of his plea or criminal background, Delino said the court should take into consideration Holmes’ past history of substance starting at the age of 6. The nature of his injuries during his arrest was also characterized as “severe” by medical personnel, Delino wrote.

Delino wrote that his client still faces state charges for the vehicle thefts he is charged with. He asked for a sentence within the guideline range in the case, which is between 30 and 37 months.