Decided: December 14, 2015
The Fourth Circuit vacated and remanded.
Lance Antonio Williams (“Williams”) appeals the decisions of the Middle District of North Carolina that ruled he was ineligible for a sentence reduction. Williams argues that Guidelines Amendment 780 revised § 3582(c)(2)’s policy statement covering sentence reductions, thus qualifying him for relief. Williams had originally pled guilty to distributing cocaine base, and prior to his plea, the U.S. Attorney filed notice that Williams’ previous North Carolina drug conviction would be used to enhance his sentence. They then calculated the proper sentence, and after Williams’ filed a pro se motion for a sentence reduction under 18 U.S.C. § 3582(c)(2), the district court denied his motion because his sentence was based on a statutory mandatory minimum, as opposed to the Guidelines range that had been lowered. This appeal followed.
The Fourth Circuit began by determining that the standard of review for the case was de novo. The Court first summarized the principles behind sentence reductions. Primarily, the Court relies on the idea that the Commission has the power to “abrogate precedent in the courts of appeals,” and has the power to set and amend the guidelines where it sees fit. Therefore, the Court recognized that the “precedent in the sentence-reduction context must give way if it conflicts with the Commission’s amendments.” The Court then looked at U.S. v. Hood, the case the district court relied on its decision. Specifically, the Court looked at its then-treatment of Amendment 706, which at the time did not impact any of the provisions in Guidelines section 5K1.1, and because of that, could not provide relief per § 3582(c)(2). However, following Hood and the subsequent circuit split, the Commission passed Guidelines Amendment 780, which modified § 3582(c)(2) relief. This Amendment, reasoned the Court, changes the outcome of Hood, so the district court’s reliance on that case was wrong. The Amendment “explicitly provides that a defendant in Williams’s situation is eligible for a § 3582(c)(2) sentence reduction.” After rejecting the applicability of Hood, the Court then turned to the question of whether Williams was eligible for a sentence reduction under Guidelines section 1B1.10. Going through the factors, the Court determined that Williams was indeed eligible for such a reduction; however, because the amount of the reduction Williams is eligible for is a “decision for the sentencing court,” the Fourth Circuit vacated the judgment of the lower court and remanded the case.
Jennie Rischbieter