Koons v. United States
138 S. Ct. 1783
| SCOTUS | 2018Background
- Five defendants (Koons, Putensen, Feauto, Gutierrez, Gardea) pleaded guilty to methamphetamine conspiracy offenses carrying statutory mandatory minimums under 21 U.S.C. §841(b)(1).
- At sentencing the district court calculated advisory Guidelines ranges but found the Guidelines maxima below the statutory mandatory minimums and therefore treated the mandatory minimums as controlling.
- The Government filed §3553(e)/§5K1.1 motions for downward departures based on the defendants’ substantial assistance; the court granted downward departures and imposed sentences below the mandatory minimums.
- In determining the extent of the downward departures, the court considered only the substantial-assistance factors (USSG §5K1.1) and did not rely on the earlier-calculated Guidelines ranges, which it had discarded.
- After sentences became final the Sentencing Commission retroactively lowered certain drug Guidelines (Amendment 782); petitioners sought sentence reductions under 18 U.S.C. §3582(c)(2), arguing their sentences were "based on" the now-lowered Guidelines ranges.
- Lower courts denied relief; the Supreme Court affirmed, holding the sentences were "based on" the mandatory minimums and substantial assistance, not on the lowered Guidelines ranges.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a sentence qualifies for §3582(c)(2) relief when the district court calculated but discarded the Guidelines range because of a statutory mandatory minimum | Petitioners: calculating the Guidelines makes the sentence “based on” that range (or should have been); thus §3582(c)(2) applies | Government: the sentence was based on the mandatory minimum and substantial assistance, not the Guidelines; therefore §3582(c)(2) does not apply | Held: Not eligible — the Guidelines played no relevant part in selecting the sentence after they were discarded |
| Whether the district court erred by using §3553(e)/§5K1.1 to depart without anchoring the departure to the advisory Guidelines range | Petitioners: §3553(e) requires sentencing “in accordance with the guidelines,” implying the guideline range must guide the departure | Government: "In accordance with the guidelines" includes following Guidelines provisions that say to discard ranges where a statutory minimum controls; reliance on substantial-assistance factors was proper | Held: No error — court permissibly discarded the advisory ranges and used substantial-assistance factors |
| Whether the Sentencing Commission’s policy statement can make defendants eligible for §3582(c)(2) relief despite statute | Petitioners: the Commission’s policy statement indicates such defendants should be eligible | Government: Policy statements cannot override the statutory threshold of §3582(c)(2) | Held: Policy statement cannot expand statutory eligibility |
| Whether the Court’s rule produces unjustified disparities | Petitioners: denying relief creates disparities compared to similarly situated defendants who benefit from retroactive amendments | Government: Identically situated defendants sentenced today would be treated the same; rule prevents arbitrary disparity | Held: No unjustifiable disparities; rule avoids them |
Key Cases Cited
- Peugh v. United States, 569 U.S. 530 (2013) (Guidelines ranges as the usual starting point in sentencing)
- Dillon v. United States, 560 U.S. 817 (2010) (limits on relief under §3582(c)(2) and role of Commission policy statements)
- United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (1906) (syllabus advisory on opinion structure)
- Koons v. United States, 850 F.3d 973 (8th Cir. 2017) (appellate decision affirmed by the Supreme Court)