United States v. Padilla-Diaz
862 F.3d 856
| 9th Cir. | 2017Background
- Three defendants (Padilla-Diaz, Heckman, Contreras Guzman) sought sentence reductions under 18 U.S.C. § 3582(c)(2) based on the Sentencing Commission’s Amendment 782 (retroactive drug‑guideline reduction).
- U.S.S.G. § 1B1.10(b)(2)(A) (effective Nov. 1, 2011) bars reducing a term of imprisonment below the minimum of the amended guideline range except for defendants who received a § 5K1.1 substantial‑assistance reduction at original sentencing.
- Each defendant had originally received a below‑guidelines sentence (downward departure/variance), and district courts denied their § 3582(c)(2) motions because their sentences were already at or below the amended guidelines’ low end.
- Defendants appealed, arguing § 1B1.10(b)(2)(A) (1) conflicts with 28 U.S.C. § 991(b), (2) violates the Fifth Amendment’s equal‑protection component, and (3) (for two defendants who pled earlier) retroactive application violates due process.
- The Ninth Circuit reviewed statutory and constitutional questions de novo and abuse of discretion for the district courts’ denials, and affirmed the denials.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 1B1.10(b)(2)(A) conflicts with 28 U.S.C. § 991(b)’s sentencing‑policy goals | § 991(b) requires flexibility to avoid unwarranted disparities; § 1B1.10 nullifies departures and thus conflicts with that mandate | § 1B1.10 is a valid Commission policy that implements limited § 3582(c)(2) reductions and does not contradict § 991(b) | No conflict; § 991(b) is a general statement of goals and does not invalidate § 1B1.10; Tercero is controlling |
| Whether § 1B1.10(b)(2)(A) violates equal protection (Fifth Amendment) | The policy irrationally favors defendants who had higher original sentences over those who had justified downward departures | The policy is rationally related to legitimate goals (simplicity, administrability, and incentive for cooperation) | No violation; classification survives rational‑basis review |
| Whether retroactive application of the 2011 version of § 1B1.10 to defendants who pled earlier violates due process | Plea agreements reserved the right to seek § 3582(c)(2) relief including reductions below the amended range; applying the new policy defeats settled expectations | Amendment 782 and its procedural limits are prospective grant of a limited benefit, not a retroactive deprivation of a preexisting right | No due‑process violation; Landgraf and St. Cyr distinguishable — change did not strip an existing benefit but limited a later‑granted benefit |
Key Cases Cited
- United States v. Tercero, 734 F.3d 979 (9th Cir. 2013) (upholding § 1B1.10(b)(2)(A) in a § 3582(c)(2) context)
- LaBonte v. United States, 520 U.S. 751 (1997) (Commission commentary yields to clear statutory language)
- Dillon v. United States, 560 U.S. 817 (2010) (§ 3582(c)(2) authorizes limited adjustments, not plenary resentencing)
- Landgraf v. USI Film Prods., 511 U.S. 244 (1994) (retroactivity analysis: fair notice, reliance, settled expectations)
- INS v. St. Cyr, 533 U.S. 289 (2001) (retroactive removal of an existing discretionary benefit can violate due process)