United States v. Bryan Williams
512 F. App'x 594
| 6th Cir. | 2013Background
- Williams pleaded guilty to three counts of crack cocaine trafficking and one count of being a felon in possession of a firearm.
- District court sentenced Williams to 135 months’ imprisonment and denied a § 3582(c)(2) motion seeking a sentence reduction.
- Amendment 750 lowered the § 2D1.1(c) base offense level for crack offenses and Amendment 759 made it retroactive.
- Williams was subject to a twenty-year mandatory minimum which exceeded the otherwise applicable guideline range.
- The district court’s departure and the use of the mandatory minimum were the basis for Williams’s sentence, not the amended base offense level.
- The Sixth Circuit held that Williams’s sentence was not “based on” a lowered guidelines range and therefore was ineligible for § 3582(c)(2) relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams’s sentence was based on a range lowered by Amendment 750 | Williams argues the base level was lowered by Amendment 750. | The district court started from the mandatory minimum, not the amended range. | No; sentence was based on the mandatory minimum, not the lowered range. |
| Whether Amendment 750 lowers Williams’s applicable guideline range | Notes to § 1B1.10 allegedly show applicable range is before departures. | Mandatory minimum replaces the guideline range when greater than the range. | Amendment 750 does not lower Williams’s applicable guideline range due to the mandatory minimum. |
| Whether the substantial-assistance mechanism could allow a below-minimum sentence despite Amendment 750 | Note 3 to § 1B1.10 could permit below-minimum sentences for substantial assistance. | Note 3 does not apply when the mandatory minimum governs the sentence. | Note 3 does not authorize a reduction here; Amendment 750 still does not apply. |
Key Cases Cited
- United States v. Johnson, 564 F.3d 419 (6th Cir. 2009) (mandatory minimum governs despite Amendment 706)
- United States v. McPherson, 629 F.3d 609 (6th Cir. 2011) (reaffirmed ineligibility when mandatory minimum exceeds range)
- United States v. Jackson, 678 F.3d 442 (6th Cir. 2012) (discussed amendments and retroactivity under § 2D1.1 and FSA)
- United States v. Hameed, 614 F.3d 259 (6th Cir. 2010) (mandatory minimum can supersede amended range; ‘based on’ analysis)
- United States v. Carradine, 621 F.3d 575 (6th Cir. 2010) (FSA retroactivity and guidelines interaction)