United States v. James Slaughter, 697 F. App'x 343

James Slaughter, a federal prisoner, was convicted in 1999 of conspiracy and multiple counts of distributing and possessing with intent to distribute cocaine base and related offenses; he received concurrent long-term sentences including life imprisonment and multi-hundred-month terms.
Slaughter filed a pro se motion under 18 U.S.C. § 3582(c)(2) seeking sentence reduction based on United States Sentencing Guidelines Amendment 782 (reduced drug sentencing ranges).
He argued a reduction would not pose a danger to the public and challenged enhancements applied at his original sentencing for drug quantity and his role in the conspiracy.
The district court implicitly found him eligible for relief under Amendment 782 but denied a reduction after considering the 18 U.S.C. § 3553(a) factors.
On appeal, Slaughter contended the court improperly relied on sentencing findings not charged in the indictment and not found beyond a reasonable doubt.
The panel noted that challenges to factual findings made at original sentencing are not cognizable in § 3582(c)(2) proceedings and reviewed the denial for abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eligibility and relief under § 3582(c)(2) / Amendment 782	Slaughter sought a sentence reduction under Amendment 782	Court implicitly found eligibility but must weigh § 3553(a) factors before granting reduction	Court treated him as eligible but denied relief after applying § 3553(a) factors
Reliance on original sentencing findings (drug quantity, role)	Those findings went beyond indictment and were not proven beyond a reasonable doubt, so they should not be considered	Such factual issues arise from original sentencing and are not reviewable in a § 3582(c)(2) motion	Court may consider original sentencing findings; challenges to them are not cognizable in § 3582(c)(2) proceedings
Public-danger / § 3553(a) factors	Slaughter argued his criminal history, offense conduct, and post‑sentencing conduct favor reduction and show no danger	Court found those factors weighed against a reduction	Appellate court held the district court considered § 3553(a) and did not abuse discretion in denying reduction
Abuse of discretion standard	N/A (Slaughter claimed error)	Denial reviewed for abuse of discretion—legal error or failure to consider required factors	No abuse of discretion; disagreement with weight given to factors is insufficient to overturn

United States v. Evans, 587 F.3d 667 (5th Cir. 2009) (factual challenges from original sentencing are not cognizable in § 3582(c)(2) motions)
Dillon v. United States, 560 U.S. 817 (2010) (district court must consider § 3553(a) factors when deciding whether a § 3582(c)(2) reduction is warranted)
United States v. Larry, 632 F.3d 933 (5th Cir. 2011) (noting district court’s implicit eligibility finding and reiterating § 3582(c)(2) procedure)
United States v. Henderson, 636 F.3d 713 (5th Cir. 2011) (disagreeing with the district court’s weighing of § 3553(a) factors is not enough to show abuse of discretion)

AFFIRMED.