United States v. Powell, 2:18-cr-00111

In 2019, Antonio Jamerson pled guilty to armed robbery and use of a firearm in relation to a crime of violence, resulting in a 124-month prison sentence (40 months for robbery, 84 months mandatory for firearm offense).
Probation calculated his offense level at 22 with a Criminal History Category III, making him eligible for guideline ranges of 51-63 months (armed robbery) and a consecutive 84-month minimum (firearm count).
Amendment 821 to the Sentencing Guidelines, effective November 1, 2023, retroactively reduces some offenders' "status points" in criminal history calculations, potentially lowering sentencing ranges.
Jamerson moved for a sentence reduction and appointment of counsel under Amendment 821, claiming applicability due to his criminal history status points.
The court denied both the motions for sentence reduction and appointment of counsel in April 2024, finding statutory limitations and the facts of Jamerson's case precluded relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Applicability of Amendment 821 to Jamerson	Government: Sentence not lowered by amendment due to mandatory minimum and original sentence structure	Jamerson: Status point reduction should lower his sentence under new guidelines	Court held Amendment 821 does not lower his guideline range because of mandatory minimum and original sentence below minimum of amended range
Eligibility for sentence reduction	Not eligible due to mandatory minimum	Eligible since he received status points	Not eligible due to statutory mandatory minimum and original sentence structure
Appointment of counsel for resentencing	Moot issue due to merits outcome	Sought counsel for resentencing process	Denied as moot, given denial of sentence reduction
Application of § 3553(a) factors	Reduction not warranted	Sought leniency under §3553(a)	Even if eligible, reduction not warranted by §3553(a) factors

None cited with official reporter citations.