United States v. Lance Williams, 808 F.3d 253

Lance Williams pleaded guilty in 2008 to distributing cocaine base; a prior North Carolina felony triggered a statutory 240‑month mandatory minimum under 21 U.S.C. § 841(b)(1)(A).
PSR produced an advisory Guidelines range (after acceptance) of 130–162 months, but USSG § 5G1.1(b) made the 240‑month statutory minimum the guideline sentence.
Prosecutors filed a § 3553(e)/5K1.1 motion for substantial assistance; the district court departed and imposed 180 months (25% below the statutory minimum).
Years later Williams moved under 18 U.S.C. § 3582(c)(2) for a reduction based on retroactive Guideline amendments (Amendments 750 and 782) that would lower his offense level and yield an advisory range of 77–96 months.
The district court denied relief relying on United States v. Hood (4th Cir. 2009), reasoning Williams’s sentence was based on a statutory minimum and the substantial‑assistance departure, not on an amendable Guidelines range.
The Fourth Circuit majority vacated and remanded, holding Amendment 780 (2014) revised USSG § 1B1.10(c) to treat amended guideline ranges “without regard to” § 5G1.1 and thus makes Williams eligible for § 3582(c)(2) relief; the amount of reduction remains discretionary.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Williams is eligible for a § 3582(c)(2) reduction after retroactive Guideline amendments when his original sentence was below the statutory minimum due to a § 3553(e) substantial‑assistance departure	Williams: Amendment 780 clarifies § 1B1.10(c) and requires ignoring § 5G1.1 when calculating the amended guideline range, so Amendments 750/782 lower his applicable Guideline range and make him eligible	District court/amicus: Hood controls — the sentence was ‘‘based on’’ the statutory minimum and the § 3553(e) departure, not on an amendable Guidelines range, so § 3582(c)(2) does not apply	Majority: Amendment 780 supersedes the pre‑existing approach; Williams is eligible because the amended guideline range (calculated without regard to § 5G1.1) is lower than his original range; remanded for discretionary reduction consideration

Dillon v. United States, 560 U.S. 817 (2010) (two‑step inquiry and requirement to follow USSG § 1B1.10 in § 3582(c)(2) proceedings)
United States v. Hood, 556 F.3d 226 (4th Cir. 2009) (held sentences reduced for substantial assistance below statutory minimum were not eligible for § 3582(c)(2) relief)
United States v. Goines, 357 F.3d 469 (4th Cir. 2004) (recognizing Sentencing Commission’s power to change circuit law via clarifying amendments)
In re Sealed Case, 722 F.3d 361 (D.C. Cir. 2013) (held defendants who received substantial‑assistance departures could be eligible for § 3582(c)(2) relief)
United States v. Savani, 733 F.3d 56 (3d Cir. 2013) (adopted approach similar to D.C. Circuit regarding § 3582(c)(2) eligibility)
United States v. Turner, 59 F.3d 481 (4th Cir. 1995) (acknowledging Commission’s authority to resolve circuit splits by amendment)