United States v. MEDINA, 1:06-cr-00232

In 2006 Medina was indicted for conspiracy to distribute ≥5 kg cocaine; in 2009 he pleaded guilty to Count One under a Rule 11(c)(1)(C) plea. Parties stipulated he was accountable for ≥150 kg, yielding a base offense level of 38 and the government sought a 4‑level role enhancement (total offense level 40).
Under the original Guidelines (level 40, CH I) the range was 292–365 months, but the parties’ 11(c)(1)(C) agreement called for a 180‑month sentence; the court adopted that sentence in April 2010.
Amendment 782 (and retroactive Amendment 788), effective November 1, 2014, lowered drug offense ranges ("all drugs minus two"); Medina’s offense level would drop from 40 to 38, yielding a revised range of 235–293 months.
Medina filed a § 3582(c)(2) motion seeking a sentence reduction under Amendment 782 because his Guidelines range was subsequently lowered.
The court applied the two‑step Dillon framework: (1) eligibility under § 3582(c)(2) and U.S.S.G. § 1B1.10; (2) if eligible, consideration of § 3553(a) factors.
The court denied the motion at step one: Medina’s imposed sentence (180 months) is already below the minimum of the amended Guidelines range (235 months), and no §5K1.1 government motion for substantial assistance was filed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Medina is eligible for a § 3582(c)(2) reduction based on Amendment 782	Medina: his Guidelines range was lowered by Amendment 782 so § 3582(c)(2) permits a reduction	Government/Court: §1B1.10(b)(2)(A) forbids reducing a sentence below the minimum of the amended range; Medina’s 180‑month term is already below that minimum	Denied — ineligible because sentence is below amended Guidelines minimum
Whether the substantial‑assistance exception allows a reduction below the amended minimum	Medina: (implicitly) should be eligible for a reduction	Government/Court: no §5K1.1 motion or government motion for substantial assistance was filed; downward departure was due to the 11(c)(1)(C) agreement, not substantial assistance	Denied — exception inapplicable without government §5K1.1 motion

Dillon v. United States, 560 U.S. 817 (sets two‑step framework for § 3582(c)(2) reductions)
In re Sealed Case, 722 F.3d 361 (D.C. Cir.) (analysis of whether a sentence was "based on" a Guidelines range in the Rule 11(c)(1)(C) context)
Freeman v. United States, 564 U.S. 522 (addresses what it means for a sentence to be "based on" a Guidelines range)
United States v. Epps, 707 F.3d 337 (D.C. Cir.) (focus on district court reasons when assessing relevance of Guidelines range)
United States v. Aguilar‑Vargas, 209 F. Supp. 3d 139 (D.D.C.) (identifies the ordinary evidentiary sources for Dillon step‑one analysis)