United States v. Juan Gonzalez Castaneda, 704 F. App'x 803

Castaneda pled guilty in Jan. 2012 to conspiracy to possess ≥5 kg cocaine aboard a U.S. vessel; factual proffer stated 401 kg and that he was the vessel’s captain.
Parties waived a full PSR; an abbreviated PSR calculated offense level 37 (base 38 for quantity, +2 captain, -3 acceptance) -> range 210–262 months.
At the combined plea/sentencing hearing the court used total offense level 35 (range 168–210 months) and sentenced to 168 months; the PSR was not amended and the record did not clearly state why the two-level reduction from 37 to 35 was applied.
The sentencing transcript includes an ambiguous remark by the government referencing “521.2 [sic]” and §2D1.1, which could indicate application of the §5C1.2 safety‑valve via U.S.S.G. §2D1.1(b)(16) (2011) or instead a discretionary downward variance.
Castaneda moved under 18 U.S.C. §3582(c)(2) for a reduction based on Amendment 782 (retroactive two‑level drug guideline reduction); the government and district court relied on the PSR calculations and denied relief, concluding the amended range would not lower the range on which his original sentence was based.
The Eleventh Circuit vacated and remanded because the record is unclear whether the unexplained two‑level reduction was a guideline‑based adjustment (thus must be reapplied when calculating the amended guideline range) or a variance (which must be excluded).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Castaneda is eligible for relief under 18 U.S.C. §3582(c)(2) given an unexplained two‑level reduction at sentencing	Castaneda: the two‑level reduction was a guideline adjustment (e.g., §2D1.1(b)(16) safety‑valve), so Amendment 782 would lower his applicable guideline range and make him eligible	Government: the reduction was a discretionary downward variance not part of the guideline calculation, so Amendment 782 would not change the guideline range on which his sentence was based and §3582(c)(2) relief is unavailable	Court: remanded to district court to make a factual finding. If reduction was a variance, no §3582(c)(2) relief; if it was under §2D1.1 (e.g., §2D1.1(b)(16)), Castaneda is eligible and court must proceed to the discretionary §3553(a) analysis

United States v. Williams, 557 F.3d 1254 (11th Cir.) (standard of review for §3582(c)(2) legal questions)
United States v. Glover, 686 F.3d 1203 (11th Cir.) (purpose of §3582(c)(2) is to give defendant the sentence he would have received under amended guidelines)
United States v. Bravo, 203 F.3d 778 (11th Cir.) (two‑step §3582(c)(2) analysis: eligibility then district court discretion)
Dillon v. United States, 560 U.S. 817 (Sup. Ct.) (framework for §3582(c)(2) reductions and application of policy statements)
United States v. Gonzalez‑Murillo, 852 F.3d 1329 (11th Cir.) (apply §1B1.1(a) steps; exclude departures/variances when calculating amended guideline range)
United States v. Vautier, 144 F.3d 756 (11th Cir.) (principle of substituting amended guideline only, leaving other application decisions intact)
United States v. Moore, 541 F.3d 1323 (11th Cir.) (no §3582(c)(2) relief where amendment did not alter the sentencing range on which the original sentence was based)
United States v. Hamilton, 715 F.3d 328 (11th Cir.) (remand for factual findings necessary to determine §3582(c)(2) eligibility)