United States v. Ledoux, 1:19-cr-00068

Jonathan Ledoux, the defendant, filed a motion to reduce his sentence under 18 U.S.C. § 3582(c)(2), citing Amendment 821 to the U.S. Sentencing Guidelines.
Amendment 821 provides retroactive sentence reductions for certain offenders, specifically those with no prior criminal history or those subject to fewer “status points.”
Ledoux was convicted of attempted coercion and enticement of a minor under 18 U.S.C. § 2422(b).
His presentence report indicated a criminal history score of zero.
The Court conducted the required two-step review: (1) whether the amendment lowered the sentencing range, and (2) whether the § 3553(a) factors warranted reduction.
Ledoux also requested appointment of counsel to assist with his motion.

Issue	Ledoux's Argument	Government's Argument	Held
Eligibility for reduction under Amendment 821	Amendment 821 applies retroactively; he is a zero-point offender; should receive a sentence reduction	He is ineligible because his offense is excluded by Amendment 821 (sex offense against a minor)	He is ineligible as his conviction is a sex offense against a minor
Appointment of counsel	Requests counsel for assistance with sentence reduction motion	No right to counsel in sentence modification proceedings	No counsel appointed, as motion has no merit

United States v. Hunter, 12 F.4th 555 (6th Cir. 2021) (Setting out post-sentencing modification standards under § 3582(c)(2)).
United States v. Jones, 980 F.3d 1098 (6th Cir. 2020) (Explaining two-step sentencing reduction analysis).
Dillon v. United States, 560 U.S. 817 (2010) (Describing the two-step framework for § 3582(c) sentence reductions).
Pennsylvania v. Finley, 481 U.S. 551 (1987) (Clarifying right to counsel applies only to first appeal of right, not collateral proceedings).