United States v. Leon Coleman
692 F. App'x 725
| 4th Cir. | 2017Background
- Defendant Leon Coleman appealed the district court’s denial of a sentence reduction under 18 U.S.C. § 3582(c)(2) based on Sentencing Commission Amendment 782.
- Coleman had pleaded guilty under Fed. R. Crim. P. 11(c)(1)(C) to an agreed 360-month term.
- The plea agreement ascribed an offense level of 43 using the murder guideline and a murder cross-reference (USSG §§ 2A1.1, 2D1.1(d)).
- Coleman argued Amendment 782 (which reduced certain drug guideline ranges) should lower his applicable guideline range and make him eligible for § 3582(c)(2) relief.
- The district court denied relief; Coleman appealed. The Fourth Circuit reviewed whether Amendment 782 affected his applicable Guidelines range and whether his Rule 11(c)(1)(C) sentence made him ineligible.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Amendment 782 lowered Coleman’s applicable guideline range | Amendment 782 reduced drug guideline ranges and thus should lower Coleman’s range | Coleman was sentenced under a murder cross‑reference (offense level 43), not under the § 2D1.1(c) provision amended by 782 | Amendment 782 did not affect Coleman’s applicable guideline range; no eligibility for § 3582(c)(2) relief |
| Whether a Rule 11(c)(1)(C) agreed sentence permits § 3582(c)(2) reduction | Coleman contended the amendment should still permit reduction | The sentence was fixed by the Rule 11(c)(1)(C) agreement and not tied to a particular Guidelines range or term within a range | A Rule 11(c)(1)(C) agreed sentence that is not based on a Guidelines range bars § 3582(c)(2) relief |
Key Cases Cited
- United States v. Williams, 808 F.3d 253 (4th Cir. 2015) (procedure for substituting retroactive amendments and leaving other guideline decisions unchanged)
- Dillon v. United States, 560 U.S. 817 (2010) (two-step process for § 3582(c)(2) reductions)
- United States v. Mann, 709 F.3d 301 (4th Cir. 2013) (standard of review for § 3582(c)(2) decisions)
- United States v. May, 855 F.3d 271 (4th Cir. 2017) (Rule 11(c)(1)(C) agreed sentences not tied to a Guidelines range are ineligible for § 3582(c)(2) reduction)