United States v. Quintanilla

Defendants in these consolidated appeals present essentially the same question of law: whether each defendant was entitled to a two-level reduction under Amendment 782 to the United States Sentencing Guidelines, which permits such a reduction for sentences based on the drug quantity under USSG 2D1.1, when the original sentence in each case was calculated starting from the higher guideline range for career offenders under USSG 4B1.1. The Fifth Circuit held that the sentences in these appeals were not "based on" section 2D1.1's drug quantity range but rather on section 4B1.1's higher career offender guideline range. Therefore, the district court was without authority as a matter of law to modify the sentences and the court reversed the judgments of the district court. View "United States v. Quintanilla" on Justia Law