United States v. Christie, 736 F.3d 191

In 2003 Christie pled guilty to crack-cocaine and firearms offenses; plea stipulated to 150–500 grams of crack and an adjusted offense level that yielded a Guidelines range resulting in a 168‑month sentence (Criminal History Category V), imposed in 2004.
In 2010 the district court granted Christie’s first § 3582(c)(2) motion (2007 crack amendment) and reduced his sentence to 151 months (bottom of the amended range at that time).
After the 2011 Guidelines amendment further lowered crack penalties, Probation and the Government agreed Christie’s amended Guidelines range was 120–150 months and that he was eligible for a § 3582(c)(2) reduction.
Christie moved in 2012 for a further reduction to 120 months; the Government opposed, citing firearms offenses and criminal history.
On January 4, 2013 the district court denied Christie’s second § 3582(c)(2) motion using a one‑page form order (AO 247) that checked “denied” but gave no case‑specific reasoning or explanation.
The Second Circuit vacated and remanded because the district court’s unexplained denial prevented meaningful appellate review of whether the court properly exercised its discretion under § 3582(c)(2) and § 3553(a).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court’s unexplained denial of a § 3582(c)(2) motion is reviewable and requires remand	Christie: lack of any case‑specific reasons prevents meaningful appellate review and therefore the denial must be vacated and remanded	Gov’t: reasoning can be inferred from the record (PSR, parties’ filings, prior sentencing history) so remand is unnecessary	The court held the unexplained form denial was insufficient; vacated and remanded because the record does not reveal the district court’s reasons and appellate review is precluded

Dillon v. United States, 560 U.S. 817 (2010) (two‑step framework for § 3582(c)(2) reductions: eligibility under § 1B1.10, then discretionary § 3553(a) inquiry)
Cavera v. United States, 550 F.3d 180 (2d Cir. 2008) (appellate review requires an adequate statement of reasons to ensure a district court exercised discretion reasonably)
United States v. Fernandez, 443 F.3d 19 (2d Cir. 2006) (court’s reasoning can sometimes be inferred from the record, but explanation need not address every argument)
United States v. Main, 579 F.3d 200 (2d Cir. 2009) (de novo review whether sentence was "based on" a Guidelines range later lowered by the Commission)
United States v. Mock, 612 F.3d 133 (2d Cir. 2010) (eligibility under § 3582(c)(2) requires consistency with U.S.S.G. § 1B1.10)
United States v. Burrell, 622 F.3d 961 (8th Cir. 2010) (vacatur where record did not show how district court exercised discretion on § 3582(c)(2) motion)
United States v. Marion, 590 F.3d 475 (7th Cir. 2009) (one‑sentence denial without reasoning insufficient; some minimal explanation required)