United States v. Alejandro Alaniz, 961 F.3d 998

In 1997 Alejandro Alaniz was convicted of multiple drug offenses and sentenced to life imprisonment under the then-mandatory Sentencing Guidelines.
In 2014 the Sentencing Guidelines were amended retroactively, lowering the applicable range for Alaniz to 360 months to life.
Alaniz moved under 18 U.S.C. § 3582(c)(2) for a sentence reduction; the district court reduced his term to 384 months.
Alaniz sought further reduction and requested reconsideration (and in effect asked for a sentence below the amended range, which the district court lacked authority to impose). The district court denied reconsideration.
The Probation Office prepared an eligibility report (quoted by the district court) describing Alaniz as a drug-conspiracy leader who issued threats to obstruct the investigation; Alaniz had the report and disputed aspects of it before the reconsideration ruling.
The Eighth Circuit (per curiam) affirmed the denial of further reduction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether due process required an evidentiary hearing before ruling on a §3582(c)(2) motion	Alaniz: the court should have held an evidentiary hearing to address prejudicial information relied on by the court	Government/District Court: no protected liberty interest in discretionary sentence reductions; movant had the eligibility report and an opportunity to respond	Held: No. Due process does not require a hearing; no abuse of discretion because Alaniz received the report and could respond
Whether the district court inadequately explained why it denied a larger reduction	Alaniz: court failed to cite facts specific to him or his offense to justify denying further reduction	Government/District Court: court quoted the eligibility report and considered §3553(a) factors; need not provide lengthy or formulaic explanation	Held: Sufficient explanation. Quoting the eligibility report (detailing leadership and obstruction threats) provided adequate basis for appellate review

United States v. Tollefson, 853 F.3d 481 (8th Cir. 2017) (de novo review of due-process challenge to sentence-reduction ruling)
United States v. Johnson, 703 F.3d 464 (8th Cir. 2013) (no constitutional liberty interest in discretionary sentence-reduction benefits)
Town of Castle Rock v. Gonzales, 545 U.S. 748 (2005) (benefits granted at officials' discretion are not protected entitlements)
United States v. Foster, 575 F.3d 861 (8th Cir. 2009) (district court abuses discretion when movant lacks opportunity to respond to prejudicial information)
United States v. Burrell, 622 F.3d 961 (8th Cir. 2010) (review for abuse of discretion; courts must consider applicable factors and give some rationale)
United States v. Boyd, 819 F.3d 1054 (8th Cir. 2016) (appellate review requires sufficient information showing district court considered sentencing factors)
Dillon v. United States, 560 U.S. 817 (2010) (limitations on courts' authority to resentence below guideline ranges)