United States v. Padilla, 1:10-cr-00789

Defendant Joshua Quazain Robinson was convicted for involvement in an international drug trafficking organization, accountable for 9 kg of cocaine and 3 kg of heroin.
Robinson originally received an 188-month federal sentence, later reduced to 121 months following Amendment 782 to the Sentencing Guidelines.
Following the retroactive application of Amendment 821, Robinson’s criminal history points were reduced from eight to six, altering his Guidelines range to 108–135 months.
Robinson sought another sentence reduction under 18 U.S.C. § 3582(c)(2) and Amendment 821, arguing for a reduction to 108 months—the bottom of the new range.
The Government opposed further reduction, pointing to Robinson’s serious criminal conduct and history.
The court previously noted Robinson has nearly completed his state sentence, with projected federal release in July 2026.

Issue	Robinson's Argument	Government's Argument	Held
Eligibility for Relief under Amendment 821	Amendment 821 reduces criminal history points, qualifying for new lower Guidelines.	Acknowledges eligibility under new range.	Court agrees: Guidelines range is now 108-135 months.
Application of 18 U.S.C. § 3553(a) Factors	New sentence warranted; 13-month reduction won’t affect deterrence or justice.	Sentence reduction not justified given offense seriousness and history.	No further reduction warranted under § 3553(a) factors.
Impact of Post-Conviction Rehabilitation	Completion of programs and good conduct support reduction.	Positive conduct expected but not extraordinary; not determinative.	Post-conviction conduct not sufficient for reduction.
Adequacy of Existing Sentence	Sentence at low end of new range, should be further reduced.	121 months already appropriate and at bottom of prior range.	Current sentence of 121 months remains just and sufficient.

Dillon v. United States, 560 U.S. 817 (sets out two-step process for § 3582(c)(2) sentence reductions)
Poindexter v. United States, 556 F.3d 87 (restates courts' limited ability to modify sentences)
United States v. Butler, [citation="501 F. App'x 8"] (post-conviction rehabilitation may be considered but does not require sentence reduction)