Koons v. United States
138 S. Ct. 1783, 584 U.S. 700, 2018 U.S. LEXIS 3382 (2018)
Rule of Law:
A defendant is not eligible for a sentence reduction under 18 U.S.C. §3582(c)(2) if their original sentence was 'based on' statutory mandatory minimums and substantial assistance to the Government, rather than on a Guidelines sentencing range that was subsequently lowered.
Facts:
- Timothy D. Koons, Kenneth Jay Putensen, Randy Feauto, Esequiel Gutierrez, and Jose Manuel Gardea (petitioners) pleaded guilty to methamphetamine conspiracy offenses.
- These offenses subjected petitioners to statutory mandatory minimum sentences under 21 U.S.C. §841(b)(1).
- Before imposing sentences, the District Court calculated the petitioners' advisory Guidelines ranges, but these ranges fell below the applicable statutory mandatory minimum sentences.
- The District Court discarded the advisory Guidelines ranges because the mandatory minimums superseded them, as instructed by the Guidelines.
- The Government filed motions under 18 U.S.C. §3553(e) because petitioners had provided substantial assistance in the investigation or prosecution of other drug offenders.
- The District Court departed downward from the mandatory minimums, imposing final sentences based on petitioners' substantial assistance, considering only the 'substantial-assistance factors' in USSG §5K1.1(a) and not the original discarded Guidelines ranges.
Procedural Posture:
- Timothy D. Koons, Kenneth Jay Putensen, Randy Feauto, Esequiel Gutierrez, and Jose Manuel Gardea were convicted of drug conspiracy charges in District Court and sentenced.
- Years after petitioners' sentences became final, the Sentencing Commission issued amendment 782, which retroactively reduced the Guidelines' base offense levels for their drug offenses.
- Petitioners sought sentence reductions under 18 U.S.C. §3582(c)(2) in the lower courts, arguing their sentences were 'based on' the now-lowered drug Guidelines ranges.
- The lower courts held that petitioners were not eligible for sentence reductions because they could not show their sentences were 'based on' the lowered Guidelines ranges.
- The United States Court of Appeals for the Eighth Circuit affirmed the lower courts' decision, ruling that petitioners' sentences were not 'based on' the lowered Guidelines ranges (850 F.3d 973).
- The Supreme Court of the United States granted certiorari to review the question presented.
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Issue:
Does a defendant qualify for a sentence reduction under 18 U.S.C. §3582(c)(2) when their original sentence was imposed below a statutory mandatory minimum due to substantial assistance, after the advisory Guidelines range (which fell below the mandatory minimum) was discarded and subsequently lowered by the Sentencing Commission?
Opinions:
Majority - Justice Alito
No, a defendant does not qualify for a sentence reduction under 18 U.S.C. §3582(c)(2) when their original sentence was imposed below a statutory mandatory minimum due to substantial assistance, because their sentences were 'based on' those mandatory minimums and their substantial assistance, not on a subsequently lowered Guidelines range. For a sentence to be 'based on' a lowered Guidelines range for purposes of §3582(c)(2), the range must have played 'a relevant part in the framework the sentencing judge used' in imposing the sentence, as established in Hughes v. United States. In these cases, the District Court calculated the advisory Guidelines ranges but then 'scrapped' them entirely in favor of the mandatory minimums, never considering the ranges again in determining the ultimate sentences. Therefore, the Guidelines ranges played no relevant role. The Court rejected petitioners' counterarguments: (1) While Guidelines ranges are a 'starting point for every sentencing calculation' (Peugh v. United States), this does not mean every sentence is 'based on' them; what matters is the role the range played in the selection of the final sentence, not merely its initial calculation. (2) The District Court made no error in sentencing; it properly discarded the advisory ranges and permissibly considered only substantial assistance factors, thereby sentencing 'in accordance with the guidelines' as required by §3553(e). (3) A Sentencing Commission policy statement cannot make a defendant eligible for a reduction under §3582(c)(2) if the statute itself makes them ineligible, as the Commission's power is limited by the statute (Dillon v. United States). (4) The Court's rule avoids, rather than creates, sentencing disparities by ensuring that identically situated defendants sentenced today would also be ineligible for reductions under §3582(c)(2).
Analysis:
This case provides crucial clarification on the statutory interpretation of 'based on a sentencing range' within 18 U.S.C. §3582(c)(2), particularly for defendants whose sentences are influenced by statutory mandatory minimums and substantial assistance departures. It establishes that the actual operative factor in the sentencing decision, rather than an initial, discarded calculation, dictates eligibility for retroactive sentence reductions. This ruling consequently limits the applicability of §3582(c)(2) for a specific class of defendants who received sentences below mandatory minimums due to their cooperation, thereby affecting a significant portion of drug-related sentences.
