United States v. Chavez-Meza
2017 U.S. App. LEXIS 6432
| 10th Cir. | 2017Background
- Chavez-Meza pleaded guilty (2013) to methamphetamine conspiracy; original Guidelines range 135–168 months and he was sentenced to 135 months (low end).
- The Sentencing Commission amended the Guidelines lowering the offense level; the revised Guidelines range became 108–135 months.
- Chavez-Meza moved under 18 U.S.C. § 3582(c)(2) for a reduced sentence to 108 months; the government consented to a stipulated range but did not specify a sentence.
- The district court, without a hearing, entered an AO-247 form order reducing the term to 114 months and checked that it had “taken into account” USSG § 1B1.10 and the § 3553(a) factors; it provided no further explanation.
- Chavez-Meza appealed, arguing the district court failed to adequately explain how it applied the § 3553(a) factors in selecting 114 months rather than the requested 108.
Issues
| Issue | Chavez-Meza’s Argument | Government’s Argument | Held |
|---|---|---|---|
| Whether § 3582(c)(2) requires a district court to provide an on-the-record explanation when imposing a within-Guidelines sentence in a sentence-reduction order | The district court’s bare AO-247 form is insufficient to show it considered § 3553(a); the court must state reasons so appellate review is meaningful | § 3582(c)(2) requires only consideration of § 3553(a); it does not require a specific on-the-record explanation | Court held § 3582(c)(2) does not incorporate § 3553(c)’s explanatory requirement; a completed AO-247 stating the court considered USSG § 1B1.10 and § 3553(a) suffices absent indication the court failed to consider the factors |
Key Cases Cited
- United States v. Verdin-Garcia, 824 F.3d 1218 (10th Cir. 2016) (§ 3582(c)(2) requires consideration of § 3553(a) but not § 3553(c)’s explanation requirement)
- United States v. Ruiz-Terrazas, 477 F.3d 1196 (10th Cir. 2007) (within-Guidelines sentences require only a general statement noting the guideline range and its calculation)
- Dillon v. United States, 560 U.S. 817 (2010) (sentence-reduction proceedings reflect congressional lenity for later guideline adjustments)
- United States v. Zayas-Ortiz, 808 F.3d 520 (1st Cir. 2015) (affirming unelaborated AO-247 where the record permits inference the district court considered pertinent factors)
- United States v. Trujillo, 713 F.3d 1003 (9th Cir. 2013) (circuit decision requiring more explanation in § 3582 proceedings; cited to show circuit split)
- United States v. Dorrough, 84 F.3d 1309 (10th Cir. 1996) (dicta stating courts need not make specific § 3553(a) findings in sentence-reduction orders as long as reasons are stated)