United States v. Gary Baptiste
696 F. App'x 394
| 11th Cir. | 2017Background
- Gary Baptiste filed a motion under 18 U.S.C. § 3582(c)(2) seeking a sentence reduction based on Amendment 782 to the Sentencing Guidelines.
- Amendment 782, effective November 1, 2014, reduced base offense levels for most drug quantities by two levels and appears listed in U.S.S.G. § 1B1.10(d).
- The government conceded Amendment 782 reduced Baptiste’s guideline range, making him potentially eligible for a § 3582(c)(2) reduction.
- The district court denied Baptiste’s motion with a one-sentence order that did not explain whether it found him ineligible or exercised discretion to deny a reduction.
- The Eleventh Circuit reviewed whether the district court followed the two-step process required by Dillon v. United States and related precedents (calculate amended range; then consider § 3553(a) factors in exercising discretion).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court complied with the two-step Dillon process when denying a § 3582(c)(2) motion | Baptiste argued the court failed to calculate/apply the amended guideline range and/or to consider § 3553(a) factors in its discretionary denial | The government conceded Amendment 782 reduced Baptiste’s range but argued the district court’s denial was appropriate; court’s order did not clarify which ground was relied on | Vacated and remanded: one-sentence denial was insufficient; district court must follow the two-step process and explain its reasoning, including consideration of § 3553(a) factors |
Key Cases Cited
- Dillon v. United States, 560 U.S. 817 (sets two-step process for § 3582(c)(2) reductions)
- United States v. Bravo, 203 F.3d 778 (11th Cir. 2000) (first step: calculate amended guideline; second: discretionary reduction)
- United States v. Berry, 701 F.3d 374 (11th Cir. 2012) (limited grounds for § 3582(c)(2) relief)
- United States v. Douglas, 576 F.3d 1216 (11th Cir. 2009) (form order insufficient to show § 3553(a) consideration)
- United States v. Williams, 557 F.3d 1254 (11th Cir. 2009) (vacatur where record silent on § 3553(a) consideration)
- United States v. Eggersdorf, 126 F.3d 1318 (11th Cir. 1997) (record may show adequate consideration without detailed factor-by-factor analysis)