United States v. Chapman, 24-60369

Roslyn Demetrius Chapman was serving a 199-month prison sentence for a controlled substance offense.
Chapman filed a motion under 18 U.S.C. § 3582(c)(2) to reduce her sentence, citing Amendment 821 to the U.S. Sentencing Guidelines.
The Government opposed the reduction, citing multiple disciplinary infractions by Chapman, including a November 2023 drug infraction.
Chapman argued the November 2023 drug infraction was due to prescribed weight loss medication, not illicit drug use.
The district court denied her motion, finding a reduction inappropriate in light of her disciplinary history and the factors set out in 18 U.S.C. § 3553(a).
Chapman appealed, asserting that the district court failed to resolve whether the November 2023 infraction was legitimate.

Issue	Chapman's Argument	Government's Argument	Held
Need for explicit finding on single infraction	Court had to resolve legitimacy of 2023 infraction	Multiple infractions justified denial regardless	No error; single infraction not critical
Requirement for hearing under Rule 32	Sentencing hearing required under Rule 32	§ 3582(c)(2) motions aren’t full resentencing	No hearing required for § 3582(c)(2) proceedings
Weight of disciplinary history on sentence	Single contested infraction decisive	Entire disciplinary history is relevant and sufficient	District court may consider total history, not single
Abuse of discretion standard	Court abused discretion by not resolving dispute	No abuse; ample basis for denial present	No abuse of discretion; denial affirmed

United States v. Calton, 900 F.3d 706 (5th Cir. 2018) (confirms abuse of discretion standard in reviewing denial of § 3582(c)(2) motions)
United States v. Rabhan, 540 F.3d 344 (5th Cir. 2008) (further clarifies standards for reviewing sentence modification motions)
Dillon v. United States, 560 U.S. 817 (2010) (clarifies that § 3582(c)(2) proceedings are not plenary resentencing hearings, but limited sentence modifications)