United States v. Meridyth, 573 F. App'x 791

James Earl Meridyth was convicted by a jury of possession with intent to distribute and conspiracy involving crack cocaine; originally sentenced to 360 months (low end of Guidelines range) and this court affirmed the conviction.
The Sentencing Commission promulgated Amendments (706, 750, etc.) reducing crack-cocaine offense levels and made the reductions retroactive under U.S.S.G. § 1B1.10, enabling relief under 18 U.S.C. § 3582(c)(2).
Meridyth moved under § 3582(c)(2) for a sentence reduction based on those amendments; the government opposed a full reduction citing his extensive criminal history and violent behavior.
The district court recalculated Meridyth’s offense level (to 34) and applicable Guidelines ranges but, after weighing the § 3553(a) factors (criminal history, prison discipline/violence, deterrence, public protection, and ongoing mental-health treatment), reduced his sentence only to 300 months.
Meridyth appealed, arguing the district court abused its discretion by not reducing his sentence further and by failing to grant a downward departure for mental impairment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion by denying a greater reduction under 18 U.S.C. § 3582(c)(2) after Guidelines amendments	Meridyth: court should have given a full reduction to the amended Guidelines range (or greater reduction)	Govt: district court properly considered § 3553(a) factors and merited a lesser reduction given his criminal history and prison conduct	Affirmed — court acted within its discretion to limit reduction to 300 months after considering § 3553(a) factors
Whether Meridyth was entitled to a downward departure for mental impairment in § 3582(c)(2) proceeding	Meridyth: noted mental-health treatment and medication; sought downward departure	Govt: § 3582(c)(2) is not the proper vehicle for a new downward-departure motion; district court properly treated mental health as a § 3553(a) factor	Affirmed — mental health considered under § 3553(a), but a § 3582(c)(2) motion cannot be used to obtain a new downward departure

Dillon v. United States, 560 U.S. 817 (2010) (two-step framework for § 3582(c)(2) reductions and requirement to consider § 3553(a) factors)
United States v. Osborn, 679 F.3d 1193 (10th Cir. 2012) (review standard and district-court discretion for § 3582(c)(2) reductions)
United States v. Meridyth, 364 F.3d 1181 (10th Cir. 2004) (prior appellate decision affirming conviction)
United States v. Lewis, 625 F.3d 1224 (10th Cir. 2010) (Fair Sentencing Act nonretroactivity and context for Guidelines changes)