United States v. Ike Florence, Jr., 503 F. App'x 796

Florence, Jr. appeals a district court decision denying further reduction of his sentence under 18 U.S.C. § 3582(c)(2) and Amendment 750.
The district court recalculated Florence’s guidelines using the amended ranges and determined an amended range of 292–365 months, lower than the pre-amendment 324–405 months.
Florence was sentenced as a career offender under U.S.S.G. § 4B1.1, which ordinarily yields a high base offense level.
Amendment 750 retroactively altered crack cocaine/criminal quantity tables, resulting in a total offense level that, after adjustments, supported a lower range based on marijuana equivalence.
The court recognized that reductions under § 3582(c)(2) are discretionary and affirmed the district court’s decision not to further reduce Florence’s sentence, given the amended range and lack of substantial assistance.
The panel reaffirmed that a court may not reduce below the bottom of the amended range absent a government substantial‑assistance motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Florence is eligible for a § 3582(c)(2) reduction after Amendment 750.	Florence argues eligibility under the amended range applies.	Career offender status frames the calculation; Moore-based reasoning may limit relief.	Eligible for reduction, but discretionary denial upheld.
Whether the district court complied with the two-step analysis required by § 3582(c)(2) and § 1B1.10.	Record shows application of amended range and consideration of factors.	Court failed to articulate every § 3553(a) factor explicitly.	Two-step analysis satisfied; court properly considered § 3553(a) factors.
Whether Florence could be reduced below the bottom of the amended range.	The court should reduce as much as possible under § 3582(c)(2).	Cannot go below the amended range absent government substantial assistance.	No reduction below the amended range without substantial‑assistance motion; affirmed denial.

United States v. James, 548 F.3d 983 (11th Cir. 2008) (establishes standard of review for § 3582(c)(2) determinations)
United States v. Jules, 595 F.3d 1239 (11th Cir. 2010) (abuse-of-discretion standard; proper procedures in § 3582(c)(2) decisions)
United States v. Bravo, 203 F.3d 778 (11th Cir. 2000) (two-step framework for § 3582(c)(2) proceedings)
United States v. Williams, 557 F.3d 1254 (11th Cir. 2009) (recalculates guideline range using amended provisions)
Eggersdorf v. United States, 126 F.3d 1318 (11th Cir. 1997) (adequacy of appellate record to reflect § 3553(a) factor consideration)
United States v. Moore, 541 F.3d 1323 (11th Cir. 2009) (career offenders not entitled to § 3582(c)(2) reductions where base offense levels not under § 2D1.1)
United States v. Lawson, 686 F.3d 1317 (11th Cir. 2012) (Moore remains binding where applicable to career offenders)
Freeman v. United States, 564 U.S. __ (2011) (retroactive amendments and eligibility considerations for § 3582(c)(2))
Liberse, 688 F.3d 1198 (11th Cir. 2012) (no reduction below amended range absent substantial assistance)