United States v. Draper
3:19-cr-00136
N.D. Miss.Nov 5, 2024Background
- Mac Arthur Draper pled guilty to distributing methamphetamine after selling 108.37 grams over six transactions.
- He was sentenced in August 2020 to 100 months in prison, with an initial sentencing guideline range of 100-125 months based on Criminal History Category IV (8 points, including 2 status points).
- Amendment 821 to the U.S. Sentencing Guidelines reduced the application of status points, lowering Draper's category to III and guideline range to 87-108 months.
- Draper sought a reduction of his sentence to 87 months under 18 U.S.C. § 3582(c)(2), arguing eligibility due to the guideline amendment.
- The government conceded eligibility under the amended guidelines, but opposed reduction based on § 3553(a) factors, citing Draper's extensive criminal history and disciplinary issues.
- Draper emphasized his minimal disciplinary record, participation in prison programs, and substance abuse struggles as grounds for sentence reduction.
Issues
| Issue | Draper's Argument | Government's Argument | Held |
|---|---|---|---|
| Eligibility for sentence reduction under § 3582(c)(2) | Eligible for reduction due to guideline change lowering criminal history | Concedes eligibility | Eligible |
| Whether § 3553(a) factors support reduction | Minimal infractions, seeks rehabilitation, has engaged in positive courses | Sentence reflects seriousness and public protection due to criminal record and infractions | Reduction not warranted |
| Seriousness of offense and criminal history | Focuses on positive steps and drug disorders | Emphasizes past violent and drug-related crimes and prison disciplinary record | No reduction |
| Public safety and rehabilitation | Argues for supervised, earlier release for rehabilitation | Maintains that longer sentence protects public and provides more rehabilitation opportunity | No reduction |
Key Cases Cited
- Dillon v. United States, 560 U.S. 817 (2010) (sets forth the two-step analysis for sentence modification based on guideline amendments)
- Chavez-Meza v. United States, 585 U.S. 109 (2018) (district courts need only provide enough explanation for appellate review)
- United States v. Evans, 587 F.3d 667 (5th Cir. 2009) (addresses standard for reviewing § 3582(c)(2) denials)