United States v. Bryan Maxwell
676 F. App'x 337
5th Cir.2017Background
- Bryan Maxwell, a federal prisoner, moved under 18 U.S.C. § 3582(c)(2) for a sentence reduction based on Amendment 484 to the Sentencing Guidelines.
- The district court denied the § 3582(c)(2) motion without stating reasons; Maxwell appealed.
- A § 3582(c)(2) reduction is available only if an amendment listed in U.S.S.G. § 1B1.10(d) lowers the defendant’s applicable guidelines range.
- Maxwell’s original sentence was calculated under the career-offender guideline, U.S.S.G. § 4B1.1, not the drug-quantity table amended by Amendment 484.
- Because the career-offender offense level controlled (it was higher than the otherwise applicable offense level), Amendment 484 did not lower Maxwell’s applicable guideline range, making him ineligible for relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion by denying the § 3582(c)(2) motion without stating reasons | Maxwell: court must state reasons; remand for explanation | Government: no requirement to state findings; denial proper because Maxwell ineligible | No abuse; denial affirmed (even if reasons required, error would be harmless because Maxwell is ineligible) |
| Whether Amendment 484 lowered Maxwell’s applicable Guidelines range | Maxwell: Amendment 484 warrants reduction | Government: sentence based on career-offender § 4B1.1, so Amendment 484 does not affect range | Amendment 484 did not lower the applicable range; Maxwell ineligible under § 1B1.10(a)(2)(B) |
| Whether Anderson remains controlling in this Circuit | Maxwell: (implicitly) Anderson should not bar relief | Government: Anderson controls; career-offender precludes § 3582(c)(2) relief | Anderson remains binding; Maxwell cited no authority to the contrary |
| Whether § 3582(c)(2) is the proper vehicle to challenge career-offender application or Johnson-based infirmity | Maxwell: could challenge career-offender status or Johnson infirmity | Government: § 3582(c)(2) is not the proper vehicle for those challenges | Court: § 3582(c)(2) improper for those challenges; other avenues may be available (e.g., direct appeal, collateral review) |
Key Cases Cited
- United States v. Jones, 596 F.3d 273 (5th Cir.) (standard of review for § 3582(c)(2) reductions)
- Dillon v. United States, 560 U.S. 817 (2010) (framework for sentence reductions under § 3582(c)(2))
- United States v. Evans, 587 F.3d 667 (5th Cir.) (no requirement to state findings when denying § 3582(c)(2) motion)
- United States v. Anderson, 591 F.3d 789 (5th Cir.) (career-offender guideline can render defendant ineligible for § 3582(c)(2) relief)
- United States v. Hinkle, 832 F.3d 569 (5th Cir.) (addressing qualifying offenses on direct appeal)
- Johnson v. United States, 135 S. Ct. 2551 (2015) (constitutional challenge to ACCA provision relied on for related argument)
- Beckles v. United States, 136 S. Ct. 2510 (2016) (Supreme Court grant of certiorari on career-offender/Guidelines issue noted)
The judgment of the district court denying Maxwell’s § 3582(c)(2) motion is affirmed.