United States v. Aguilar-Vargas
209 F. Supp. 3d 139
| D.D.C. | 2016Background
- William Aguilar-Vargas pled guilty under a Rule 11(c)(1)(C) plea agreement to conspiracy to distribute cocaine/cocaine base; the parties agreed to a specific term and the court accepted the plea.
- The plea was modified pre-sentencing so the agreement called for a 108-month (nine-year) sentence, below the statutory 120-month mandatory minimum because the defendant qualified for the Safety Valve.
- At sentencing the court calculated an applicable Guidelines range of 70–87 months (offense level 27, CH I), a range that would have been lowered to 57–71 months under Amendments 782/788.
- Aguilar-Vargas moved under 18 U.S.C. § 3582(c)(2) (as amended by retroactive application of Amendment 782 via Amendment 788) seeking a reduced term; defense counsel filed an unopposed motion seeking a 94-month reduction.
- The central legal question was whether Aguilar-Vargas’s imposed 108-month sentence was “based on” the subsequently-lowered Guidelines range so as to permit a § 3582(c)(2) reduction.
- The court denied the motions, concluding the sentence was not “based on” the Guidelines range but instead on the binding Rule 11(c)(1)(C) agreement and the court’s statement that it was bound to impose that agreed sentence irrespective of the Guidelines calculation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 3582(c)(2) authorizes a sentence reduction when original sentence came from a Rule 11(c)(1)(C) plea | Aguilar-Vargas argued Amendments 782/788 lowered his calculated Guidelines range (70–87 to 57–71), so his sentence qualifies for reduction | Court/Defendant (government) argued the 108-month term was imposed because the court was bound by the 11(c)(1)(C) agreement and thus was not "based on" the Guidelines range | Denied — sentence not "based on" a subsequently-lowered Guidelines range; defendant ineligible for § 3582(c)(2) reduction |
| Whether routine calculation of Guidelines at plea/sentencing makes a Rule 11(c)(1)(C) sentence eligible for § 3582(c)(2) | Aguilar-Vargas asserted the court’s calculation of the 70–87 range makes him eligible | Court held that routine/preliminary Guidelines calculations do not automatically make an 11(c)(1)(C) sentence "based on" that range | Denied — routine calculation insufficient to confer eligibility |
| Whether Safety Valve usage affects eligibility for § 3582(c)(2) | Defense implied Safety Valve eligibility (which allowed sentence below statutory minimum) might permit a reduction | Court noted Safety Valve eligibility does not automatically preclude § 3582(c)(2) relief but is not dispositive here | Held — Safety Valve status does not save the motion where court’s reasoning shows sentence was based on plea agreement |
| Proper focus for "based on" analysis | Aguilar-Vargas relied on plea agreement language and drug-quantity admission | Court emphasized focus must be on district court’s reasons (plea/sentencing transcripts) rather than the mere fact of a Guidelines calculation | Held — district court’s statements show the sentence was imposed because it was bound by the plea, not the Guidelines |
Key Cases Cited
- Dillon v. United States, 560 U.S. 817 (statutory two-step for § 3582(c)(2) relief)
- Freeman v. United States, 564 U.S. 522 (plurality on Rule 11(c)(1)(C) sentences and § 3582(c)(2) eligibility)
- In re Sealed Case, 722 F.3d 361 (D.C. Cir. approach: sentence "based on" Guidelines to the extent Guidelines informed judge's decision)
- United States v. Epps, 707 F.3d 337 (D.C. Cir. application of Freeman plurality in Rule 11(c)(1)(C) context)
- United States v. Duvall, 705 F.3d 479 (Rule 11(c)(1)(C) acceptance binds court to agreed sentence)
- United States v. Cook, 594 F.3d 883 (routine Guidelines calculation does not automatically make sentence "based on" that range)