United States v. Meridyth, 701 F. App'x 722

James Meridyth was convicted of multiple federal drug-trafficking offenses and originally sentenced to 360 months (the Guidelines minimum). The conviction was affirmed on appeal.
The Sentencing Commission subsequently lowered the Guidelines range twice, prompting two § 3582(c)(2) motions by Meridyth seeking sentence reductions.
After the first amendment, the district court reduced Meridyth’s sentence from 360 to 300 months (a one‑sixth reduction), citing his extensive criminal history and prison disciplinary infractions among other § 3553(a) considerations.
After a second amendment, the district court again granted a one‑sixth reduction (from 300 to 250 months), referring back to its earlier memorandum and noting Meridyth had no reported misconduct since March 2012.
Meridyth argued the district court abused its discretion by giving the same proportional reduction the second time despite his improved prison conduct and rehabilitation efforts; he contended the court was required to grant a proportionally greater reduction on the second motion.
The Tenth Circuit affirmed, holding the district court did not abuse its discretion and was not required to assign a particular weight to post‑sentencing conduct or to increase the proportional reduction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion by granting the same one‑sixth § 3582(c)(2) reduction on a second motion despite improved post‑sentencing conduct	Meridyth: improved disciplinary record and rehabilitation warranted a proportionally greater reduction the second time	Government/District Court: § 3582(c)(2) grants district courts discretion; no legal rule requires a larger reduction for improved conduct	Affirmed: No abuse of discretion; court properly considered § 3553(a) factors and post‑sentencing conduct (which it may but need not give particular weight to)

Pepper v. United States, 562 U.S. 476 (2011) (post‑sentencing rehabilitation may support a downward variance at resentencing)
Dillon v. United States, 560 U.S. 817 (2010) (§ 3582(c)(2) proceedings are limited sentence‑reduction proceedings, not plenary resentencings)
Chavez‑Meza v. United States, 854 F.3d 655 (10th Cir. 2017) (abuse‑of‑discretion standard for § 3582(c)(2) rulings)
United States v. Meridyth, 364 F.3d 1181 (10th Cir. 2004) (appellate decision affirming Meridyth’s conviction)
United States v. Miller, 832 F.3d 703 (7th Cir. 2016) (remand where district court improperly characterized infractions and failed to consider positive prison evidence)
United States v. Ruiz–Terrazas, 477 F.3d 1196 (10th Cir. 2007) (standards concerning appellate review of discretionary sentencing decisions)
United States v. Kennedy, 225 F.3d 1187 (10th Cir. 2000) (limits on supplementing the appellate record)