United States v. Edmond, 4:96-cr-00174

Edmond pled guilty to three-count information (robbery affecting interstate commerce counts 1 and 2; possession of firearm during crime count 3) under a binding Rule 11(e)(1)(C) plea, with a joint sentence of 271 months.
Edmond was designated a career offender under USSG § 4B1.1, leading to a higher guideline range.
Original calculations: base offense level 29 and criminal history VI produced a 151–188 month range; two 5-level enhancements for brandishing a firearm on counts 1 and 2 increased the level to yield a combined level 29.
Because of the career-offender designation, the guideline range is calculated under § 4B1.1, resulting in a total offense level of 32 and a total sentence range of 271–308 months (including a 120-month mandatory consecutive term for count 3).
Amendment 599 retroactively clarifies how a weapon enhancement is applied to the underlying offense; the court must apply the amendment to determine if the defendant’s range is lowered.
The court concluded that Amendment 599 does not lower Edmond’s applicable guideline range because the career-offender calculation remains unchanged, and thus the defendant is not eligible for a § 3582(c)(2) reduction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Amendment 599 lowers Edmond’s guideline range	Edmond contends the amendment would reduce the range	The career-offender calculation remains unchanged by Amendment 599	No; Amendment 599 does not lower the range
Whether the court has jurisdiction to reduce sentence under § 3582(c)(2)	N/A	If range is not lowered, § 3582(c)(2) jurisdiction fails	Yes; court lacks jurisdiction to reduce sentence

United States v. Alcala, 352 F.3d 1153 (7th Cir. 2003) (guideline adjustments for brandishing firearms in § 924(c) context)
United States v. Pleasant, 704 F.3d 808 (9th Cir. 2013) (Amendment 599 retroactive applicability)