Koons v. United States

Those whose sentences are “based on” mandatory minimums and substantial assistance to the Government do not qualify for sentence reductions under revised “Guideline ranges.”

Petitioners were convicted under drug conspiracy. In its sentencing decision, the District Court first calculated the advisory Guideline “ranges” accordingto the United States Sentencing Commission. Pursuant to the Guidelines Manual, the court imposed the mandatory minimum sentence instead of the range under the Guidelines, because the range fell below the mandatory minimum. After discarding the Guideline ranges, Under 18 U.S.C. §3553(e), the court lowered the mandatory minimum sentence for the Petitioners in accordance with their substantial assistance in the prosecution of other drug offenders. Following the finalization of Petitioners’ sentences, the Sentencing Commission lowered the base offense levels for certain drug offenses under the Guideline ranges. Petitioners sought reductions under the now-lowered Guideline ranges, but were denied based on failure to show their sentences were “based on”the Guideline ranges. 18 U.S.C. §3582(c)(2). The Supreme Court affirmed, finding that the sentences imposed by the District Court were not founded in the Guideline ranges, but on the statutory mandatory minimum. The Court further stated that the court below properly disregarded the ranges and issued the Petitioners’sentences according to the mandatory minimum and Petitioners’ cooperation with law enforcement. AFFIRMED.