United States v. Johnson
701 F. App'x 33
| 2d Cir. | 2017Background
- Defendant Layne Johnson was originally sentenced in the EDNY to 78 months’ imprisonment; original Guidelines range was 78–97 months.
- The Sentencing Guidelines were later amended such that Johnson’s range would be 63–78 months.
- Johnson moved under 18 U.S.C. § 3582(c)(2) for a sentence reduction to reflect the amended Guidelines.
- The district court denied the § 3582(c)(2) motion after considering the § 3553(a) factors and maintained the 78-month sentence.
- Johnson appealed, arguing the denial was an abuse of discretion and that his sentence was procedurally and substantively unreasonable.
- The plea agreement waived appeal of sentences of 108 months or less; the Second Circuit affirmed the district court’s order.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Johnson was eligible for relief under § 3582(c)(2) | Johnson: eligible because Guidelines were later lowered | Government: parties agreed he was eligible | Court: Johnson is eligible (parties agreed) |
| Whether the district court abused its discretion in denying a sentence reduction under § 3582(c)(2) | Johnson: 78 mo. was low-end originally but high-end under amended range; court should reduce | Government: district court properly weighed § 3553(a) factors and declined reduction | Court: no abuse of discretion; district court properly considered factors and denied reduction |
| Whether the district court relied improperly on immutable or irrelevant factors | Johnson: court focused on policy goals and disciplinary record, which he claims he cannot control | Government: court is required to consider § 3553(a) factors, including seriousness, deterrence, and prison conduct | Court: consideration of those factors was proper; no indication of disproportionate weight on disciplinary record |
| Whether the resulting sentence was procedurally or substantively unreasonable | Johnson: challenges recast § 3582 arguments; alleges unreasonableness | Government: plea waiver and sound district-court discretion foreclose relief | Court: no meaningful procedural challenge; substantive argument unpersuasive; plea waiver also limits appeal |
Key Cases Cited
- Dillon v. United States, 560 U.S. 817 (2010) (establishes two-step inquiry for sentence reductions under § 3582(c)(2))
- United States v. Mock, 612 F.3d 133 (2d Cir. 2010) (discusses eligibility and consistency with Sentencing Commission policy guidance)
- United States v. Borden, 564 F.3d 100 (2d Cir. 2009) (standard of review: abuse of discretion for district court’s § 3582(c)(2) decisions)
- United States v. Figueroa, 714 F.3d 757 (2d Cir. 2013) (district courts may consider prison disciplinary record when imposing sentence)