United States v. Jorge Beltran-Estrada, 990 F.3d 1124

Background

In 2013 Jorge Beltran-Estrada pleaded guilty to possession with intent to distribute ≥50 grams methamphetamine and was sentenced to 235 months (bottom of the 2013 Guidelines range).
In 2014 the Sentencing Commission adopted Amendment 782 (retroactive two-level base offense reduction); Beltran-Estrada moved under 18 U.S.C. § 3582(c)(2) for a reduced sentence, also citing his good conduct.
The U.S. Probation Office prepared a memorandum recalculating a reduced Guidelines range (listed as 188–210 months), identified eight alleged in-custody conduct violations, and recommended 199 months.
The district court granted a reduction to 199 months. Beltran-Estrada moved for reconsideration, asking for 188 months and an evidentiary hearing on the alleged violations; the court denied reconsideration.
On appeal Beltran-Estrada argued (1) denial of procedural due process/right to be heard at resentencing, (2) violation of USSG §6A1.3’s opportunity-to-present-information requirement, and (3) that the court gave an inadequate explanation rendering the reduction procedurally unreasonable.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Beltran-Estrada was denied procedural due process/right to be heard in a §3582(c)(2) proceeding	Beltran-Estrada: he was not given an adequate opportunity to be heard before the court relied on the Probation memo and alleged violations	Government/district court: defendant received the Probation memo, chance to rebut and submit mitigating evidence, and thus adequate notice and opportunity	Court: No due process violation; defendant was apprised of and had access to the information and opportunity to respond
Whether USSG §6A1.3 required a hearing of the type Beltran-Estrada requested	Beltran-Estrada: §6A1.3 entitles him to an adequate opportunity to present disputed information, which required the evidentiary hearing he sought	Government: §6A1.3 (even if applicable) does not mandate a particular form of hearing; notice and chance to respond suffice	Court: Even assuming §6A1.3 applies, it does not require the hearing requested; the court provided adequate notice and opportunity
Whether the district court’s explanation for imposing 199 months was inadequate, making the sentence procedurally unreasonable	Beltran-Estrada: the district court gave only a brief statement and adopted the Probation memo, which is insufficient explanation	Government: In §3582 proceedings a district court need only give some explanation; adopting a party’s rationale can suffice	Court: The court provided enough explanation to permit meaningful appellate review; no abuse of discretion
Whether the district court abused discretion in denying reconsideration and refusing to reduce to the low end (188 months)	Beltran-Estrada: district court should have granted further reduction and held evidentiary hearing on violations	Government: sentencing reduction was discretionary; 199 months was reasonable given conduct considerations	Court: Affirmed district court’s discretionary choice and denial of reconsideration

Key Cases Cited

United States v. Lewis, 827 F.3d 787 (8th Cir. 2016) (describing Amendment 782’s two-level reductions)
United States v. Johnson, 703 F.3d 464 (8th Cir. 2013) (standard: de novo review for constitutional and statutory challenges; abuse-of-discretion for §3582 adjustments)
United States v. Foster, 575 F.3d 861 (8th Cir. 2009) (defendant must be apprised of information on which court rests its decision)
United States v. Alaniz, 961 F.3d 998 (8th Cir. 2020) (no constitutionally protected liberty interest in a discretionary sentence reduction)
United States v. Neal, 611 F.3d 399 (7th Cir. 2010) (applying USSG §6A1.3 to §3582 proceedings)
United States v. Mercado-Moreno, 869 F.3d 942 (9th Cir. 2017) (declining to extend §6A1.3 to §3582 proceedings)
United States v. Burrell, 622 F.3d 961 (8th Cir. 2010) (court must give some explanation of reasoning in granting a §3582 reduction)