United States v. Betts, 20-40331

Darrin Lashaon Betts pleaded guilty in 2015 under Federal Rule of Criminal Procedure 11(c)(1)(C) to possession with intent to distribute methamphetamine.
At sentencing in the Eastern District of Texas the district court applied Sentencing Guidelines Amendment 782 (a two‑level reduction in base offense levels for certain drug offenses).
Betts moved under 18 U.S.C. § 3582(c)(2) seeking a sentence reduction based on Amendment 782.
Betts relied on Hughes v. United States, arguing that because the Government and the court had acknowledged the guidelines range at sentencing and he received no benefit from the plea, he should be eligible for a reduction.
The district court denied the § 3582(c)(2) motion, explaining Amendment 782 had already been applied and that the court would have imposed the same sentence even without the guidelines.
Betts appealed, and the Fifth Circuit reviewed the denial for abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion in denying a § 3582(c)(2) reduction based on Amendment 782 given a Rule 11(c)(1)(C) plea and the court/Gov's acknowledgment of the guidelines at sentencing	United States: No abuse — Amendment 782 was already applied at sentencing, so no further reduction is available.	Betts: Under Hughes, acknowledgment of the guidelines and no plea benefit make him eligible for a reduction.	Affirmed — no abuse of discretion; Amendment 782 already accounted for and court said the sentence would have been the same without the guidelines.

Hughes v. United States, 138 S. Ct. 1765 (2018) (addressing when acknowledgment of the Guidelines affects § 3582(c)(2) eligibility)
United States v. Henderson, 636 F.3d 713 (5th Cir. 2011) (sets two‑step § 3582(c)(2) framework and abuse‑of‑discretion review)