United States v. Mario Seymour
677 F. App'x 258
| 6th Cir. | 2017Background
- Mario Seymour pled guilty to conspiracy to manufacture and distribute cocaine base, cocaine, and marijuana under 21 U.S.C. §§ 841(a)(1), 846; plea agreement recommended 151 months.
- PSR calculated offense level 36, CHC II → guidelines 210–262 months; parties stipulated offense level 32; district court treated the Guidelines as advisory, used level 34 → range 168–210 months, and imposed 151 months.
- Sentencing Commission retroactively amended U.S.S.G. § 2D1.1 (Amendment 782), potentially lowering defendant’s Guidelines range.
- Seymour moved under 18 U.S.C. § 3582(c)(2) for a sentence reduction based on Amendment 782; the district court denied relief, concluding the amended range (168–210 months) did not permit reducing below its minimum.
- Seymour appealed, arguing his sentence was “based on” a Guidelines range such that § 3582(c)(2) authorized a reduction; the government and courts examined whether the plea agreement explicitly tied the 151-month term to a Guidelines range.
- The Sixth Circuit held the plea agreement did not reference a Guidelines range; thus the sentence was not "based on" a Guidelines range for § 3582(c)(2) purposes and the district court lacked authority to reduce the sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a sentence in a plea agreement is "based on" the Guidelines for § 3582(c)(2) | N/A (government/respondent) urged ineligibility | Seymour: his 151-month term was effectively based on the Guidelines so Amendment 782 could authorize a reduction | Held: Not based on Guidelines; plea did not reference a Guidelines range, so § 3582(c)(2) inapplicable |
| Whether stipulated offense level or negotiated sentence constitutes an explicit Guidelines reference | N/A | Seymour: stipulated offense level and sentencing process show reliance on Guidelines | Held: Stipulated offense level alone is not an explicit reference to a Guidelines range; plea lacked the required explicit reference |
| Whether courts may examine negotiation history to find a Guidelines basis | N/A | Seymour: courts should infer that Guidelines informed the agreed sentence | Held: Courts cannot conduct a free‑ranging inquiry into negotiations; must rely on explicit plea terms per McNeese/Freeman concurrence |
| Standard of review for § 3582 eligibility | N/A | N/A | Held: Eligibility determinations reviewed de novo; district court correctly found defendant ineligible |
Key Cases Cited
- Valentine v. United States, 694 F.3d 665 (6th Cir. 2012) (eligibility under § 3582 reviewed de novo)
- Dillon v. United States, 560 U.S. 817 (2010) (two-step framework for § 3582(c)(2) reductions)
- Freeman v. United States, 564 U.S. 522 (2011) (plurality and concurrence on when plea-agreement sentences are "based on" the Guidelines)
- McNeese v. United States, 819 F.3d 922 (6th Cir. 2016) (plea must explicitly reference a Guidelines range to be treated as "based on" Guidelines for § 3582 purposes)