Koons v. United States

Petitioners pleaded guilty to drug conspiracy charges. The district court calculated their advisory Guidelines ranges, which fell below the mandatory minimums under 21 U.S.C. 841(b)(1), and concluded that the mandatory minimums superseded the Guidelines ranges. The court departed downward under 18 U.S.C. 3553(e) to reflect substantial assistance to the government in prosecuting other drug offenders. In determining the final sentences, the court considered the Guidelines “substantial assistance factors” but did not consider the original Guidelines ranges. The Sentencing Commission subsequently amended the Guidelines and reduced the base offense levels for certain drug offenses, including those for which petitioners were convicted. A unanimous Supreme Court affirmed the denial of petitioners’ motions for sentence reductions under section 3582(c)(2), which makes defendants eligible if they were sentenced “based on a sentencing range” that was later lowered. Petitioners’ sentences were not “based on” their lowered Guidelines ranges but were “based on” their mandatory minimums and on their substantial assistance to the government. For a sentence to be “based on” a lowered Guidelines range, the range must have at least played “a relevant part [in] the framework the [sentencing] judge used” in imposing the sentence. Just because courts routinely calculate Guidelines ranges does not mean that any sentence subsequently imposed must be regarded as “based on” a Guidelines range. In this case, the district court properly discarded their Guidelines ranges and permissibly considered only factors related to substantial assistance when departing downward. Identically situated defendants sentenced today may receive the same sentences petitioners received. View "Koons v. United States" on Justia Law