United States v. Medina, Criminal No. 2006-0232

In 2006 Medina was indicted for conspiracy to distribute ≥5 kg cocaine; in 2009 he pled guilty to Count One and entered a Rule 11(c)(1)(C) plea agreeing to a 180‑month sentence.
At plea, the parties agreed Medina was accountable for ≥150 kg cocaine (base offense level 38), the government agreed to a 2‑level acceptance reduction and sought a 4‑level leadership increase, yielding offense level 40 (Guidelines 292–365 months).
The court imposed the agreed 180‑month sentence on April 9, 2010.
Amendments 782 and 788 (effective Nov. 1, 2014) reduced drug‑trafficking guideline ranges ("all drugs minus two"); Medina’s Guidelines range would drop from 292–365 (level 40) to 235–293 (level 38).
Medina moved under 18 U.S.C. § 3582(c)(2) to reduce his sentence based on Amendment 782; the court analyzed the motion under the two‑step Dillon framework.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Medina is eligible for a § 3582(c)(2) reduction based on Amendment 782	Amendment 782 lowered the applicable Guidelines range, so Medina is eligible for reduction	Medina argues his sentence was "based on" the Guidelines range and Amendment 782 applies	Denied: not eligible because his imposed sentence (180 mo.) is below the minimum of the amended range, so § 1B1.10(b)(2)(A) bars reduction
Effect of Rule 11(c)(1)(C) plea on eligibility	The 11(c)(1)(C) plea does not necessarily bar § 3582 relief; the sentencing range was still part of the analytic framework	The plea agreement and sentencing transcript should be considered to see whether range was relevant	Court: 11(c)(1)(C) plea does not automatically preclude relief, but here ineligibility follows from the policy statement, so analysis ends
Whether the court may reduce a sentence already below the amended Guidelines range	Medina seeks a lower sentence despite already being below amended range	Government contends § 1B1.10(b)(2)(A) prohibits reducing a term below the amended range minimum	Held: § 1B1.10(b)(2)(A) prohibits reducing an imposed term that is already below the amended range minimum
Application of the substantial‑assistance exception	N/A	Medina might argue exception could apply	Held: Exception § 1B1.10(b)(2)(B) inapplicable—government did not file a § 5K1.1/Rule 35 motion and sentencing reduction resulted from the 11(c)(1)(C) agreement, not substantial assistance

Dillon v. United States, 560 U.S. 817 (establishing the two‑step § 3582(c)(2) framework)
Freeman v. United States, 564 U.S. 522 (explaining how to evaluate whether a sentence was "based on" a Guidelines range in the Rule 11(c)(1)(C) context)
In re Sealed Case, 722 F.3d 361 (D.C. Cir.) (interpreting "based on" for § 3582(c)(2) and 11(c)(1)(C) pleas)
United States v. Epps, 707 F.3d 337 (D.C. Cir.) (focus on district court reasons when assessing guideline relevance)
United States v. Aguilar‑Vargas, 209 F. Supp. 3d 139 (D.D.C.) (evidence to consider: sentencing hearings, plea hearings, plea text)