United States v. ARMSTEAD
3:16-cr-00066
S.D. Ind.Jun 9, 2025Background
- Damien M. Armstead was sentenced in 2019 for possession with intent to distribute over 50 grams of methamphetamine.
- He was classified as a career offender, resulting in a criminal history category of VI and a guideline range of 188 to 235 months.
- Armstead received a total criminal history score of 10, which included 2 status points for committing the offense while under a criminal justice sentence.
- The court ultimately imposed a sentence below the guideline range, sentencing Armstead to 151 months imprisonment.
- In 2025, Armstead moved for a sentence reduction pursuant to 18 U.S.C. § 3582(c)(2) and Amendment 821 to the U.S. Sentencing Guidelines, seeking to reduce status points in his criminal history calculation.
Issues
| Issue | Armstead's Argument | Government's Argument | Held |
|---|---|---|---|
| Whether Amendment 821 entitles Armstead | He should receive sentence reduction due to reduced | Amendment does not lower guideline range due | Amendment does not lower |
| to a sentence reduction under § 3582(c)(2) | status points as per Part A of Amendment 821 | to career offender status; no basis to reduce | guideline range; reduction denied |
Key Cases Cited
- Dillon v. United States, 560 U.S. 817 (2010) (explains process for considering sentence reductions under guideline amendments)