United States v. Hugo Angel, 675 F. App'x 503

Hugo Angel pleaded guilty to conspiracy to distribute and possess with intent to distribute cocaine and was sentenced to 235 months at the top of his Guidelines range.
Sentence reflected his extensive prior criminal history, including kidnapping and transporting victims to Mexico where they were beaten and threatened.
Angel filed a pro se 18 U.S.C. § 3582(c)(2) motion seeking a sentence reduction based on the retroactive Amendment 782 to the Sentencing Guidelines.
The district court found Angel eligible under § 3582(c)(2) but denied a reduction after considering the § 3553(a) factors and Angel’s post‑sentencing misconduct (weapon possession, rioting, fighting, unauthorized items) despite his prison work and class completion.
Angel appealed, arguing the court relied on boilerplate language and failed to meaningfully consider §1B1.10 and the § 3553(a) factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Angel was eligible for a § 3582(c)(2) reduction under Amendment 782	Angel argued he qualified for a reduction under retroactive Guidelines changes	Government conceded eligibility under the amended Guideline	Court found Angel eligible but eligibility alone does not require a reduction
Whether the district court properly considered § 3553(a) factors before denying relief	Angel asserted the court used boilerplate and failed to consider required factors	Government urged consideration of prior criminal history and post‑sentence misconduct	Court expressly stated it considered §1B1.10 and § 3553(a) and denial was not an abuse of discretion
Whether the denial constituted an abuse of discretion	Angel claimed procedural error and insufficient consideration of mitigating conduct (classes, work)	Government pointed to extensive criminal history and in-prison violations as reasons to deny reduction	Appellate court held no abuse of discretion; Angel failed to show erroneous findings or legal error
Whether record required remand for further explanation	Angel argued inadequate explanation required remand	Government relied on district court’s explicit statement and record showing consideration of factors	Court affirmed; explicit statement and record sufficed, no remand required

Dillon v. United States, 560 U.S. 817 (procedural framework for § 3582(c)(2) reductions)
United States v. Henderson, 636 F.3d 713 (5th Cir. 2011) (standard of review and abuse-of-discretion guidance for § 3582(c)(2))
United States v. Smith, 417 F.3d 483 (5th Cir. 2005) (abuse-of-discretion requires legal error or clearly erroneous factual assessment)
United States v. Larry, 632 F.3d 933 (5th Cir. 2011) (§ 3582(c)(2) two-step inquiry and consideration of § 3553(a))
United States v. Evans, 587 F.3d 667 (5th Cir. 2009) (affirming denial of § 3582(c)(2) reduction based on § 3553(a) factors)