Hughes v. United States
138 S. Ct. 1765
| SCOTUS | 2018Background
- Erik Hughes entered a Rule 11(c)(1)(C) "Type‑C" plea agreeing to a 180‑month sentence; the agreement did not reference a specific Guidelines range.
- At sentencing the district court accepted the plea, calculated the Guidelines range as 188–235 months, and stated the 180‑month term was compatible with the Guidelines and §3553(a) factors.
- Shortly after sentencing the Sentencing Commission adopted Amendment 782 (made retroactive) lowering most drug offense offense levels, which would reduce Hughes’ Guidelines range to 151–188 months.
- Hughes moved under 18 U.S.C. §3582(c)(2) for a reduced sentence; the district court and Eleventh Circuit denied relief, relying on the Freeman concurrence to hold Type‑C agreements ineligible unless they expressly relied on a Guidelines range.
- The Supreme Court granted certiorari and resolved the substantive question: when is a sentence "based on" a Guidelines range for §3582(c)(2) purposes when entered under a Type‑C plea.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a sentence imposed pursuant to a Rule 11(c)(1)(C) plea is "based on" the Guidelines range for §3582(c)(2) eligibility | Hughes: Type‑C sentences are eligible when the court relied on the Guidelines as part of the framework for accepting or imposing the sentence | Government: Type‑C sentences are grounded in the parties' agreement, not the Guidelines; permitting §3582(c)(2) relief undermines the Government's bargain | A Type‑C sentence is "based on" the Guidelines if the Guidelines range was a basis for the district court's exercise of discretion in accepting or imposing the sentence; Hughes is eligible because the court relied on the Guidelines |
| Standard for determining "based on" under §3582(c)(2) | Hughes: look to whether the guidelines informed the court's decision at sentencing | Government: look to the binding nature of the plea — if the agreement dictated the sentence, the Guidelines are irrelevant | Court: "based on" means the Guidelines were part of the analytic framework the judge used; eligibility exists unless the record clearly shows the court would have imposed the same sentence irrespective of the Guidelines |
| Whether Freeman’s fractured opinions control interpretation | Hughes: plurality reasoning that Type‑C sentences can be based on Guidelines should control | Government: follow Justice Sotomayor’s Freeman concurrence (narrower rule) | Court avoided Marks inquiry and decided the underlying statutory issue on the merits, adopting the plurality’s practical rule as applied here |
| Role of district court discretion on remand | Hughes: district court should reconsider reduction under §3553(a) and policy statements | Government: relief would strip a key benefit from plea negotiation and conflict with §1B1.10 | Held: Court has discretion to reduce after considering §3553(a) and Commission policy; benefits of the plea can be weighed when deciding or sizing any reduction |
Key Cases Cited
- Freeman v. United States, 564 U.S. 522 (2011) (fractured decision on §3582(c)(2) eligibility for Type‑C pleas; plurality and concurrence provided competing tests)
- Marks v. United States, 430 U.S. 188 (1977) (framework for deriving holdings from fractured Supreme Court decisions)
- Peugh v. United States, 569 U.S. 530 (2013) (Guidelines remain the lodestone of federal sentencing even after Booker)
- Molina‑Martinez v. United States, 578 U.S. (2016) (the selected Guidelines range has systemic significance and can cause prejudice when applied erroneously)
- United States v. Booker, 543 U.S. 220 (2005) (held that the Sentencing Guidelines are advisory post‑Booker)
- Dillon v. United States, 560 U.S. 817 (2010) (interpretation of §3582(c)(2) and the Sentencing Commission’s role in retroactive amendments)