United States v. Donnell Jehan, 876 F.3d 891

Jehan was a high-ranking member of the Black Disciples charged with large-quantity drug conspiracy; he fled and later surrendered, pleaded guilty, and admitted substantial drug quantities.
The plea agreement (Rule 11(c)(1)(C)) fixed two alternative outcomes: 300 months (if the government moved under §5K1.1 for substantial assistance) or life imprisonment if not; the district court accepted the agreement and imposed 300 months.
The government later moved under Rule 35(b) and the court reduced Jehan’s sentence (a 20% reduction from 300 months).
Jehan then moved under 18 U.S.C. §3582(c)(2), invoking Amendment 782 (a 2-level reduction in drug offense base levels), seeking further reduction to 188 months.
The district court denied the §3582(c)(2) motion, reasoning the sentence was governed by a binding Rule 11(c)(1)(C) plea and not “based on” a Guidelines range affected by Amendment 782; Jehan appealed.

Issue	Jehan's Argument	Government's Argument	Held
Whether a sentence imposed under a binding Rule 11(c)(1)(C) plea that specifies a term (300 months) is "based on" the Sentencing Guidelines so as to permit relief under 18 U.S.C. §3582(c)(2) after Amendment 782	Jehan: the plea repeatedly references the Guidelines and the 300‑month term aligns with a Guidelines-derived calculation (after assumed departures), so the sentence is effectively based on the Guidelines and eligible for §3582(c)(2) relief	Government: the 300‑month agreed term is a product of a binding plea bargain (not an express link to an applicable Guidelines range), so it is not “based on” the Guidelines and §3582(c)(2) relief is unavailable	The court affirmed denial: the plea agreement does not expressly tie the 300‑month term to a Guidelines sentencing range, so the sentence is not “based on” the Guidelines for §3582(c)(2) purposes

United States v. Ray, 598 F.3d 407 (7th Cir. 2010) (explains when Rule 11(c)(1)(C) agreements are not eligible for §3582(c)(2) relief)
United States v. Dixon, 687 F.3d 356 (7th Cir. 2012) (plea agreement must expressly link sentence to Guidelines to permit §3582(c)(2) reduction)
United States v. Scott, 711 F.3d 784 (7th Cir. 2013) (adopts Sotomayor approach from Freeman on eligibility)
United States v. Guyton, 636 F.3d 316 (7th Cir. 2011) (departure vs. applicable Guidelines range explanation)
United States v. Castillo, 695 F.3d 672 (7th Cir. 2012) (departure is distinct from changing the applicable Guidelines range)
Dowell v. United States, 694 F.3d 898 (7th Cir. 2012) (ambiguities in plea agreements construed in defendant’s favor)
United States v. Taylor, 778 F.3d 667 (7th Cir. 2015) (district court retains jurisdiction to adjudicate §3582(c)(2) motions even when authority to grant relief is absent)