Hughes v. United States

Sentence reductions are available for plea deals under 18 U.S.C. § 3582(c)(2) when the guideline range is lowered, so long as the range was considered when the sentence was imposed.

Petitioner agreed to a Type-C plea agreement stipulating to a sentence of 180 months, which the court approved, after it “considered the sentencing guidelines.” The Sentencing Commission later amended the Federal Sentencing Guidelines and made them retroactive, lowering Petitioner’s Guideline range. Petitioner filed a motion seeking a reduced sentence under 18 U.S.C. § 3582(c)(2). The district court denied the motion and the Court of Appeals for the Eleventh Circuit affirmed. The Supreme Court reversed the decision, holding that relief is available under 18 U.S.C. § 3582(c)(2), permitting the district court to consider a reduction in Petitioner’s sentence when the Guideline Range is lowered, as the Guidelines were considered when the sentence was imposed. The Supreme Court further clarified that “in federal sentencing the Guidelines are the court’s starting point” and when the Guideline range is lowered, defendants will be eligible for relief “absent clear demonstration . . . the court would have imposed the same sentence regardless of the Guidelines.” The Court reasoned that this creates uniformity in sentence severity relating to the severity of a crime, as is the purpose of 18 U.S.C. § 3582(c)(2) and the Sentencing Reform Act. This decision resolves the circuit split caused by the concurrence in Freeman v. United States, 564 U.S. 522 (2011). REVERSED and REMANDED.