United States v. Craig Frazier
823 F.3d 1329
| 11th Cir. | 2016Background
- Craig Frazier, a career offender, moved under 18 U.S.C. § 3582(c)(2) for a sentence reduction based on Sentencing Commission Amendment 782, which lowered guideline offense levels for certain drug offenses.
- This was Frazier’s third § 3582(c)(2) motion and third appeal; prior motions under Amendments 706 and 750 resulted in remand and later affirmation after the district court detailed § 3553(a) reasoning.
- The district court acknowledged Frazier was eligible for a reduced guideline range under Amendment 782 but denied relief in a one-page order, citing career-offender status, post-sentencing prison infractions, an additional state murder conviction, and his leadership role in a large drug-trafficking organization.
- The court applied the two-step § 3582(c)(2) framework: recalculating the Guidelines and then exercising discretion whether to impose the new sentence after considering § 3553(a) factors and U.S.S.G. §1B1.10 commentary.
- Frazier contended Amendment 782 lowered his guideline range (even accounting for career-offender adjustment) and argued the district court abused its discretion by denying a reduction and requested reassignment of the case on remand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court abused discretion in denying § 3582(c)(2) reduction under Amendment 782 | Frazier: eligible for reduction; district court failed to properly weigh § 3553(a) and abused discretion in denying relief | Government: district court followed § 3582(c)(2) procedure and permissibly exercised discretion after considering § 3553(a) factors | No abuse of discretion; denial affirmed |
| Whether district court had to expressly discuss Fair Sentencing Act or Frazier’s positive conduct | Frazier: court should have addressed these specific points | Government: court need only show it considered pertinent § 3553(a) factors; need not address every argument explicitly | Court not required to explicitly discuss every factor; record shows § 3553(a) considered |
| Whether reassignment to a different judge on remand is warranted | Frazier: requested reassignment | Government: reassignment unnecessary; no evidence of bias | Reassignment denied as extraordinary and unnecessary |
Key Cases Cited
- United States v. Smith, 568 F.3d 923 (11th Cir.) (standard for reviewing § 3582(c)(2) discretionary denials)
- United States v. Jules, 595 F.3d 1239 (11th Cir.) (district court must apply proper legal standard and procedures)
- United States v. Bravo, 203 F.3d 778 (11th Cir.) (two-step § 3582(c)(2) analysis: recalculate and then decide whether to reduce sentence)
- United States v. Brown, 104 F.3d 1254 (11th Cir.) (district court can deny reduction by identifying pertinent § 3553(a) factors without detailed findings on each)
- United States v. Alvarado, 808 F.3d 474 (11th Cir.) (district court discretion in weighing § 3553(a) factors)
- United States v. Gupta, 572 F.3d 878 (11th Cir.) (standards for reassignment under supervisory authority)
- United States v. Shaygan, 652 F.3d 1297 (11th Cir.) (reassignment is extraordinary; consider appearance of justice and duplication costs)