Koons v. U.S.

Whether federal courts may retroactively reduce sentences under 18 U.S.C. § 3582(c)(2) if the defendant received a reduced sentence under 18 U.S.C. § 3553(e).

Petitioners, inmates convicted in federal district court for possession of methamphetamine and related crimes, received reduced sentences under 18 U.S.C. § 3553(e), which allows courts to impose sentences under the statutory minimum at the motion of the government if the defendant provides substantial assistance to the authorities. After sentencing guidelines were lowered in 2014, Petitioners sought to further reduce their sentences under 18 U.S.C. § 3582(c)(2), which allows a discretionary sentence reduction based on lowered sentencing guidelines. The district court and the Eighth Circuit held that the Petitioners were not eligible for sentence reductions because their sentences were based on statutory minimums and not on the sentencing guideline ranges lowered by 3582(c)(2). The Eight Circuit determined relief is available to defendants who enter into plea agreements in which the sentence is clearly based on a sentencing range that is subsequently lowered. On appeal to the US Supreme Court, Petitioners assert that, although their sentences were based on the statutory minimum, the sentencing guidelines remained a central consideration in their ultimate sentencing. The Fourth Circuit allows retroactive sentence reductions for defendants who received reductions for substantial assistance, while the Tenth Circuit and now the Eighth Circuit do not.