United States v. Harris, 1:11-cr-00187

James Harris was convicted in 2011 by jury of conspiracy and possession with intent to distribute cocaine and sentenced to 210 months as a career offender under U.S.S.G. § 4B1.1, with a criminal history category of VI.
Harris’s sentence included an adjustment for time served after convictions for attempted second-degree murder and robbery with a deadly weapon.
Harris’s guideline range was impacted by career offender status, which automatically set his criminal history category at VI, regardless of underlying criminal history points.
Harris filed a pro se motion in 2024 to reduce his sentence under 18 U.S.C. § 3582(c)(2), invoking Amendment 821 to the Sentencing Guidelines, which reduces status points for those on probation/parole at the time of offense.
The government opposed, arguing Harris’s status as a career offender made him ineligible for any reduction under Amendment 821, as the amendment did not change his guidelines calculation.
The district court denied the motion, finding the amendment did not affect Harris’s guideline range since career offender status supersedes status points.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eligibility for sentence reduction under Amendment 821	Amendment 821's reduced status points apply	Career offender status trumps guideline change	Not eligible; status points don't affect career offender range
Application of § 3582(c)(2) for retroactive amendment relief	Guideline range has been effectively lowered	Amendment 821 does not impact career offender	No relief; range based on career offender criteria
Impact of prior convictions on criminal history calculation	Status points reduction changes category	Category set by career offender, not status points	Status points irrelevant; still category VI
Mandate to consider sentence modifications	Courts should consider policy changes	Rule of finality/only as statute permits	No modification allowed under current retroactive amendments

Dillon v. United States, 560 U.S. 817 (2010) (outlines two-step procedure for § 3582(c)(2) sentence reductions)
Freeman v. United States, 564 U.S. 522 (2011) (explains narrow exceptions to rule of finality in criminal sentences)
United States v. Bond, 56 F.4th 381 (4th Cir. 2023) (discusses availability of sentence modifications under § 3582)
United States v. Martin, 916 F.3d 389 (4th Cir. 2019) (describes district court discretion in compassionate release and sentence modifications)
United States v. Williams, 808 F.3d 253 (4th Cir. 2015) (details two-step approach for considering retroactive guideline amendments)
United States v. Peters, 843 F.3d 572 (4th Cir. 2016) (clarifies standards for eligibility and discretion in § 3582(c)(2) motions)