United States v. Butler
130 F. Supp. 3d 317
| D.D.C. | 2015Background
- Butler and Jones were defendants in the District of Columbia for a major cocaine conspiracy led by Rayful Edmund III, sentenced in 1990 (Criminal Nos. 89-162-2 and 89-162-4).
- Butler was a leading organizer and broker of drugs; Jones was an enforcer and supervisor, both essential to the enterprise's operation.
- Butler received 405 months and Jones 393 months; PSR described Butler as indispensable and Jones as below Edmund, Lewis, and Butler in hierarchy.
- Amendment 782 (downward two levels) was enacted in 2014 with retroactive application via Amendment 788, effective November 1, 2014, but accompanied by a delayed release window.
- Defendants filed motions under 18 U.S.C. § 3582(c)(2) seeking reductions based on Amendment 782; the court applied the Dillon two-step framework and § 1B1.10.
- The court concluded although eligible for reductions, the § 3553(a) factors and public-safety considerations weigh against early release, resulting in denial of the motions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Butler and Jones are eligible for § 3582(c)(2) reductions after Amendment 782. | Butler and Jones are eligible due to retroactive amendment. | Not necessary; focus is on the two-step analysis, but eligibility exists. | Eligible for reduction, but not warranted after § 3553(a) factors. |
| Whether the § 3553(a) factors support a reduction for these defendants. | Factors permit a reduction due to post-sentencing conduct and potential disparities. | Factors weigh against release given the seriousness of offenses and leadership roles. | Unwarranted reduction; factors favor continued imprisonment. |
| Whether the court should consider post-sentencing rehabilitation and public-safety concerns in § 3582(c)(2) determinations. | Post-sentencing conduct supports some mitigation. | Rehabilitation evidence does not override the seriousness of crimes and guns-related enhancements. | Post-sentencing conduct considered but does not overcome warranted denial. |
Key Cases Cited
- Dillon v. United States, 560 U.S. 817 (2010) (two-step framework for § 3582(c)(2) proceedings)
- Lafayette v. United States, 585 F.3d 435 (D.C. Cir. 2009) (discretionary authority under § 3582(c)(2))
- Kennedy v. United States, 722 F.3d 439 (D.C. Cir. 2013) (district courts retain broad authority in § 3582(c)(2) proceedings)
- United States v. Osborn, 679 F.3d 1193 (10th Cir. 2012) (nature and circumstances of the offense proper considerations)
- United States v. Dunn, 728 F.3d 1151 (9th Cir. 2013) (criminal history permissible in § 3582(c)(2) analysis)
- United States v. Rivera, 662 F.3d 166 (2d Cir. 2011) (retroactive amendments authorize but do not require reductions)