United States v. Charles Beamus
943 F.3d 789
| 6th Cir. | 2019Background
- In 2002 Beamus was convicted of conspiracy to possess 6.68 grams of crack cocaine and related firearms offenses; a presentence report treated him as a career offender.
- Under U.S.S.G. §2D1.1 his guideline range would have been 120–150 months, but application of the career‑offender guideline §4B1.1 produced a range of 360 months–life.
- Statutorily his base exposure was set by 21 U.S.C. §841(b)(1)(B) (2002); an §851 information raised his statutory range to 120 months–life.
- The district court imposed a 420‑month sentence (360 months for the drug count concurrent with a firearm count, plus 60 months consecutive).
- Beamus moved for resentencing under the First Step Act of 2018; the district court denied relief, concluding career‑offender status made him ineligible. The government concedes error on appeal.
- The Sixth Circuit reversed and remanded, holding career‑offender status does not bar First Step Act eligibility, and remanding for the district court to exercise its discretion on resentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether career‑offender status renders a defendant ineligible for First Step Act §404 resentencing | Beamus: Eligibility turns on whether the Fair Sentencing Act modified the statutory penalties for the offense; career‑offender status is irrelevant | District court/Govt: Because career‑offender status determined the guidelines range, Beamus was not eligible | Reversed: career‑offender status does not categorically bar First Step Act relief; Beamus eligible and case remanded for discretionary resentencing |
| Whether enhancements or reliance on §851 affect First Step Act eligibility | Beamus: An §851 enhancement or reliance on prior convictions does not change that the Fair Sentencing Act altered the statutory penalties for the §841 offense | Govt: Enhancement and §851 use of prior records imply the sentence was not properly treated as modified by the Fair Sentencing Act | Held: §851 enhancement and related reliance do not defeat eligibility; eligibility is governed by whether the Fair Sentencing Act changed the statutory penalties |
Key Cases Cited
- Koons v. United States, 138 S. Ct. 1783 (2018) (interpreting what it means for a sentence to be “based on” a guidelines range under §3582(c)(2))
- United States v. Riley, 726 F.3d 756 (6th Cir. 2013) (held career‑offender status can make defendant ineligible for §3582(c)(2) relief when sentence was not based on §2D1.1)
- United States v. Perdue, 572 F.3d 288 (6th Cir. 2009) (similar holding about §3582(c)(2) and career‑offender treatment)
- United States v. Blewett, 746 F.3d 647 (6th Cir. 2013) (en banc) (holding Fair Sentencing Act not retroactive absent further congressional action)
- United States v. Potter, 927 F.3d 446 (6th Cir. 2019) (explaining First Step Act permits courts to impose reduced sentences "as if" the Fair Sentencing Act were in effect)
- United States v. Hegwood, 934 F.3d 414 (5th Cir. 2019) (First Step Act leaves resentencing decision to district court discretion)