United States v. Chantell Daniel, 508 F. App'x 549

Daniel pleaded guilty to possession and distribution of 50.6 grams of cocaine base under 21 U.S.C. § 841(a)(1).
Base offense level was 28; three-level reduction for acceptance of responsibility yielded total offense level 25.
Criminal history category VI; guideline range 110–137 months, with a mandatory minimum of 120 months applying.
District court departed downward for substantial assistance, resulting in 100–125 months and a 100-month sentence.
Amendments to the Guidelines later reduced base offense levels for crack offenses; Daniel moved for a § 3582(c)(2) sentence reduction.
District court denied the reduction; Daniel appealed, contending Amendment 750 lowers both post-departure and applicable ranges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Daniel is eligible for a § 3582(c)(2) reduction after Amendment 750.	Daniel argues Amendment 750 lowers his applicable range and the post-departure range.	The government contends the applicable range remains based on the statutory minimum; a comparable downward departure would yield the same sentence.	Not eligible; comparable downward departure yields 100 months.

United States v. McClain, 691 F.3d 774 (6th Cir. 2012) (de novo review; eligibility for § 3582(c)(2) reduction)