United States v. Kevyn Taylor, 2015 U.S. App. LEXIS 2195

Kevyn Taylor was convicted in 2009 of crack and powder cocaine offenses and firearm offenses; at sentencing the court attributed 837 g crack, 396 g powder cocaine, and 227 kg marijuana as relevant conduct.
Under the Guidelines in effect at sentencing, converting all drugs to marijuana equivalents yielded a Drug Quantity Table offense level of 36, reduced two levels by Application Note 10(D) (multi-drug reduction) to a base level of 34; adjusted offense level produced a guideline range of 188–235 months for the drug counts.
Taylor was sentenced to concurrent 180 months on the drug counts and a total term of 240 months; convictions and sentence were affirmed on direct appeal.
In 2013 Taylor moved under 18 U.S.C. § 3582(c)(2), asserting that retroactive Amendment 750 (implementing the Fair Sentencing Act changes) lowered his base offense level from 34 to 32 because it reduced the marijuana-equivalent weight of crack.
The district court dismissed the § 3582(c)(2) motion for lack of subject-matter jurisdiction, reasoning Amendment 750 also deleted Application Note 10(D) so his final guideline range was not lowered.
The Seventh Circuit affirms on the merits but clarifies that § 3582(c)(2) eligibility is non‑jurisdictional: district courts have subject‑matter jurisdiction to adjudicate § 3582(c)(2) motions even when the statutory criteria for relief are not met.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a district court has subject‑matter jurisdiction to decide a § 3582(c)(2) motion when the movant is ineligible for relief	Taylor argued the court should adjudicate his § 3582(c)(2) motion (and that Amendment 750 lowered his guidelines)	Government implicitly contended the court lacked authority to grant relief when statutory criteria aren’t met	Court holds § 3582(c)(2) limitations are non‑jurisdictional; district courts have subject‑matter jurisdiction to decide such motions
Whether Amendment 750 lowered Taylor’s applicable guideline sentencing range such that § 3582(c)(2) relief is available	Taylor relied on the portion of Amendment 750 reducing the marijuana equivalent of crack to lower his base level	Government showed Amendment 750 also deleted the two‑level multi‑drug reduction (Application Note 10(D)), resulting in no net change to Taylor’s final guideline range	Court holds Amendment 750 produced no net reduction in Taylor’s applicable guideline range; § 3582(c)(2) relief denied on the merits

United States v. Beard, 745 F.3d 288 (7th Cir. 2014) (treated § 3582(c)(2) limits as non‑jurisdictional case‑processing rule)
United States v. Taylor, 627 F.3d 674 (7th Cir. 2010) (district court may deny § 3582(c)(2) motion even if defendant is ineligible)
Freeman v. United States, 131 S. Ct. 2685 (2011) (analyzes § 3582(c)(2) availability in terms of statutory eligibility, not jurisdiction)
Arbaugh v. Y & H Corp., 546 U.S. 500 (2006) (distinguishes jurisdictional rules from statutory case‑processing limits)
United States v. Cotton, 535 U.S. 625 (2002) (defines subject‑matter jurisdiction as constitutional or statutory power to adjudicate)