Hughes v. United States

Defendant entered into a binding C plea agreement where he agreed to plead guilty to two of his original four drug and gun charges. In exchange, the government dismissed the other two charges and refrained from filing an information, which would have given the District Court formal notification of the Defendant’s prior drug felonies. After accepting the agreement, the District Court sentenced the Defendant to 180 months in prison, in accordance with the government’s recommendation. Two months after the Defendant was sentenced the Sentencing Commission adopted amendment 782 to the United States Sentencing Guidelines. The retroactive amendment reduced the base level by two levels for most drug offenses. In response, the Defendant filed a § 3582(c) motion for a sentence reduction under the Sentencing Reform Act of 1984. § 3582(c) authorizes a district court to reduce a defendant’s sentence when the defendant had been sentenced to a term of imprisonment based on a range that was later lowered by the Commission. However, the District Court denied the Defendant’s motion, stating that he was ineligible for relief because his sentence was based on his plea agreement which did not expressly rely on the Guidelines range. The Court of Appeals of the Eleventh Circuit affirmed. The question for the Supreme Court was whether a defendant who entered into a plea agreement was generally eligible for a sentence reduction if a later retroactive amendment to the relevant Sentencing Guidelines range occurred. The Supreme Court answered that question in the affirmative, holding that “a sentence imposed pursuant to a plea agreement is no exception to the general rule that a defendant’s Guidelines range is both the starting point and a basis for his ultimate sentence.” Only when the Guideline’s range is not a “relevant part of the analytic framework the judge used to determine the sentence” is the defendant’s sentence not based on the Guidelines and therefore § 3582(c) can offer no relief. The Supreme Court concluded that in this case the record showed the Guidelines sentencing range, which was later amended, was a basis for the sentence the District Court imposed. Therefore, the Defendant was eligible for a sentencing reduction.

“[R]elief under §3582(c)(2) should be available to permit the district court to reconsider a prior sentence to the extent the prisoner’s Guidelines range was a relevant part of the framework the judge used to accept the agreement or determine the sentence. If the district court concludes that it would have imposed the same sentence even if the defendant had been subject to the lower range, then the court retains discretion to deny relief.” p.1778