United States v. Carlos Watts, 670 F. App'x 890

Carlos Watts pleaded guilty under a binding Rule 11(c)(1)(C) plea agreement calling for a 156‑month sentence.
The Sentencing Commission later retroactively lowered the Guidelines range applicable to his drug conviction.
Watts moved under 18 U.S.C. § 3582(c)(2) for a sentence reduction based on the amended Guidelines range.
The district court denied relief, concluding it lacked authority to reduce a Rule 11(c)(1)(C) sentence unless the plea expressly tied the term to a Guidelines range.
The plea agreement did not reference or adopt any specific Guidelines range; it stated the parties had independently considered the Guidelines and other factors and agreed the 156‑month term was reasonable.
The parties never agreed on a Guidelines calculation at sentencing; the eventual Guidelines range (after objections) was higher than the agreed term.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 3582(c)(2) authorizes reducing a sentence imposed by a Rule 11(c)(1)(C) plea agreement that references the Guidelines generally	Watts: the agreement’s repeated references to the Guidelines make him eligible for a reduction	Government: Rule 11(c)(1)(C) sentences are based on the agreement itself unless the plea expressly uses a specific Guidelines range	Court: No reduction; plea did not expressly base the 156‑month term on any particular Guidelines range, so § 3582(c)(2) relief is unavailable

Freeman v. United States, 564 U.S. 522 (2011) (Sotomayor concurrence: Rule 11(c)(1)(C) sentences are based on the agreement unless the plea expressly uses a Guidelines range)
United States v. McNeese, 819 F.3d 922 (6th Cir. 2016) (Rule 11(c)(1)(C) sentence eligible for § 3582(c)(2) reduction only when plea explicitly references a Guidelines range)
United States v. Smith, 658 F.3d 608 (6th Cir. 2011) (reduction allowed where plea included a Guidelines calculation worksheet)