United States v. Furman Quattlebaum, 696 F. App'x 625

Furman Quattlebaum, pro se, moved under 18 U.S.C. § 3582(c)(2) for a sentence reduction based on Amendment 782 to the Sentencing Guidelines.
The district court denied the § 3582(c)(2) motion, concluding it lacked jurisdiction to reconsider a prior § 3582 ruling and noting Quattlebaum had previously been denied relief under Amendment 782.
The district court relied on circuit precedent (Goodwyn and Mann) that treated § 3582(c)(2)-based motions for reconsideration as barred on jurisdictional grounds.
After the district court’s denial but before this appeal resolved, this Court decided May, holding the prohibition on § 3582(c)(2) reconsideration is not jurisdictional and can be waived if the government fails to assert it below.
The Fourth Circuit affirmed the district court’s order but modified the rationale: relief is barred under the law-of-the-case doctrine because an earlier appeal already determined Amendment 782 did not lower Quattlebaum’s Guidelines range.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court had jurisdiction to entertain a § 3582(c)(2) motion challenging a prior denial	Quattlebaum argued the court could reconsider his sentence under Amendment 782	Government relied on precedents barring reconsideration (treated as jurisdictional)	Court affirmed denial but held the jurisdictional bar is not the operative basis; instead relief is barred by law of the case
Whether Amendment 782 lowered Quattlebaum’s Guidelines range	Quattlebaum contended Amendment 782 warranted a lower range	Government maintained Amendment 782 did not lower his range and prior rulings foreclosed relief	Earlier appellate decision already concluded Amendment 782 did not lower his range; law of the case bars relitigation
Whether May affects the district court’s failure to consider waiver of jurisdictional objections	Quattlebaum could argue May undermines the district court’s jurisdictional rationale	Government could have asserted the waiver rule below but did not need to because law of the case applies	May means jurisdictional objection can be waived, but here the dispositive bar is law of the case, so affirmance stands

United States v. Goodwyn, 596 F.3d 233 (4th Cir. 2010) (addressed limits on district courts revisiting § 3582 rulings)
United States v. May, 855 F.3d 271 (4th Cir. 2017) (holding the prohibition on § 3582(c)(2)-based reconsideration is not jurisdictional and can be waived)
United States v. Aramony, 166 F.3d 655 (4th Cir. 1999) (articulating the law-of-the-case doctrine)
United States v. Riley, 856 F.3d 326 (4th Cir. 2017) (explaining that an appellate court may affirm on any ground apparent from the record)