Chavez-Meza v. United States

Whether a district court must explain its decision when deciding not to grant a proportional sentence reduction under 18 U.S.C. § 3582(c)(2) when the reasons are not otherwise apparent from the record, or is it sufficient that the reduction is issued on a pre-printed form order containing boilerplate language as set forth in U.S.S.G. § 1B1.10 and the sentencing factors set forth in 18 U.S.C. § 3553(a).

The main question of this case hinges on the level of explanation District Court judges must give when reducing a prison sentence. Petitioner was charged with, and subsequently pled guilty to, Possession with Intent to Distribute over 1,600 grams of methamphetamine. The District Court sentenced Petitioner to 135 months imprisonment, which was the lowest end of the sentencing range. Petitioner moved the District Court to reduce his sentence under 18 U.S.C. § 3582(c)(2) which allows for sentence reductions for certain drug offenses. The purported new guidelines under this sentencing scheme changed the range to 108 to 135 months. The court subsequently reduced the sentence to 114 months. On appeal, the Tenth Circuit held that the trial court did not need to offer an explanatory statement under 18 U.S.C. § 3553(a) because the new imposed sentence was within the new lowered range. The court equated the requisite level of explanation for § 3582(c)(2) and § 3553(c) hearings. Petitioner highlights a notable circuit split on this issue, naming the Sixth, Eighth, Ninth, and Eleventh Circuits as courts that require explanation and the Fourth Fifth, and Tenth Circuits that require only internal consideration of § 3553(c) factors. Petitioner urges the Supreme Court to require District Courts to explicitly denote their consideration and explanation when modifying sentences.