United States v. Maurice LaShane Hamilton
715 F.3d 328
| 11th Cir. | 2013Background
- Hamilton challenged district court denial of § 3582(c)(2) reduction based on Amendment 750; remand ordered because original 2007 drug-quantity findings were not accurately reflected in later motions.
- Original 2007 PSI attributed drug quantities and conspiracy conduct that determined base offense level 38; Addendum later clarified group’s conduct and 1.5 kg threshold, not the earlier 12 kg figure used in some motions.
- Probation Addendum stated group operated for at least two months and that two weeks of activity yielded at least 1.5 kg crack cocaine, using a 0.75 conversion rate; district court adopted Addendum over objections to paragraphs 36 and 43.
- Amendment 750 (Nov. 2011) raised to 8.4 kg the threshold for base offense level 38; retroactivity allowed § 3582(c)(2) relief only if amendment actually lowers the defendant’s applicable guidelines range.
- The Eleventh Circuit vacated and remanded to reassess the original drug-quantity findings in light of the Addendum and ensure any reduction is based on the record before the original sentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Amendment 750 lowers Hamilton’s guidelines range | Hamilton contends original findings show only 1.5 kg, not 8.4 kg | Government/probation maintained 12 kg basis and 4.5 kg threshold under prior amendments | Remanded to determine if amendment lowers range based on original record. |
| Whether district court erred by not considering the Addendum in 3582(c)(2) analysis | Original order relied on paragraphs 36/43, ignored Addendum | Responses cited in 2011 did not reflect Addendum | Remand to reincorporate Addendum findings. |
| Whether the record at original sentencing contained adequate, specific quantity findings | If only ‘at least 1.5 kg’ was found, not enough to decide Amendment 750 impact | Record supported base level 38 via large quantity; amendment not lowering range | If findings insufficient, district court may reexamine record consistent with original proceedings. |
| What is the correct procedure for evaluating retroactive amendments under § 3582(c)(2) | Burden on Hamilton to show lowered range with Amendment 750 | Court may calculate new range but must preserve original factual determinations | Court must apply 1B1.10(b) and consider § 3553(a) factors after determining applicable amended range. |
Key Cases Cited
- United States v. Cothran, 106 F.3d 1560 (11th Cir. 1997) (stay with original factual determinations; no new findings beyond PSI)
- United States v. Davis, 587 F.3d 1300 (11th Cir. 2009) (uncontested PSI findings can support relief or denial)
- United States v. Moore, 541 F.3d 1323 (11th Cir. 2008) (amendment must lower range to authorize § 3582(c)(2) relief)
- United States v. Glover, 686 F.3d 1203 (11th Cir. 2012) (amendment must actually lower defendant’s guidelines range)
- United States v. Bravo, 203 F.3d 778 (11th Cir. 2000) (discretion to grant relief after calculating amended range)
- United States v. Hall, 600 F.3d 872 (7th Cir. 2010) (limits on new factual findings in § 3582(c)(2) proceedings)
- United States v. Anderson, 707 F.3d 973 (8th Cir. 2013) (permissible to rely on record before original sentencing)