United States v. Lucas, 3:11-cr-04461

Defendant Omar Lucas pleaded guilty to distributing crack cocaine and admitted to one sale of 79 grams; the Presentence Report attributed a total of 250.7 grams of cocaine base to him (79 g + 117 g + 54.7 g).
Sentenced in November 2012, Lucas qualified as a career offender; his offense level was set at 34 (career-offender guideline), with an adjusted offense level of 31 after acceptance, producing a Guidelines range of 188–235 months.
The court imposed a 120‑month sentence, below the Guidelines range. Lucas now seeks a § 3582(c)(2) reduction based on Amendment 782 to the Sentencing Guidelines (retroactive crack guideline reduction), asking to reduce his term to 101 months.
Amendment 782 would lower the underlying base offense level (from 30 to 28) for the 250.7‑gram quantity, but the career‑offender provision (§ 4B1.1) still fixes the offense level at 34.
Because the career‑offender offense level remains 34, the amended Guidelines range would still be controlled by the career‑offender provision; the amended non‑career range (for base level 28, CHC VI) would be 140–175 months, and Lucas’s 120‑month sentence remains below that range.
The court made a supplemental finding, by a preponderance of the evidence, that Lucas is more likely than not responsible for 250.7 grams of cocaine base.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Amendment 782 retroactively lowers Lucas’s applicable Guidelines range making him eligible for a § 3582(c)(2) reduction	Amendment 782 reduced base offense levels for crack quantities and thus lowers Lucas’s Guidelines range	Amendment 782 does not affect Lucas’s applicable Guidelines range because the career‑offender guideline controls	Denied — career‑offender provision keeps offense level at 34, so Amendment 782 does not lower Lucas’s applicable range
Whether a reduction is prohibited because the original sentence is below the low end of the amended Guidelines range	Lucas argues a reduction is warranted despite his original sentence being below amended range	Court notes policy statement generally bars reduction when original sentence is below amended low end	Denied — original sentence (120 months) is below the amended low end (140 months), so reduction is prohibited

United States v. Hernandez-Martinez, 933 F.3d 1126 (9th Cir. 2019) (describes two‑step § 3582(c)(2) eligibility inquiry and policy‑statement limits)
Dillon v. United States, 560 U.S. 817 (2010) (explains how to calculate the amended Guidelines range for § 3582(c)(2) proceedings)
United States v. Mercado-Moreno, 869 F.3d 942 (9th Cir. 2017) (endorses preponderance‑of‑the‑evidence standard for quantity findings in § 3582(c)(2) proceedings)