United States v. Ronald Hue Burch, 683 F. App'x 915

In 2002 Ronald Burch pled guilty to conspiracy to possess with intent to distribute cocaine and to possessing a firearm in relation to a drug-trafficking offense.
At sentencing his base offense level (per U.S.S.G. §2D1.1) produced a guideline range of 168–210 months for the drug count; a separate §924(c) count carried a consecutive 60-month mandatory minimum.
He received 180 months (drug count) plus 60 months consecutive (firearm), totaling 240 months.
After Amendment 782 lowered his guideline range retroactively, Burch moved under 18 U.S.C. §3582(c)(2) for a sentence reduction; the district court denied the motion in April 2015.
The district court explained its denial by reference to §3553(a) factors: the violent nature of the offense, Burch’s violent criminal history and personal involvement, public protection needs, and that his prison coursework did not outweigh those factors.
Burch’s post-judgment motion for relief (arguing insufficient articulation) was denied; he appealed and the Eleventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court sufficiently articulated reasons under §3553(a) for denying a §3582(c)(2) reduction	Burch: court did not adequately explain why it denied reduction and failed to credit rehabilitation / coursework	Government: district court considered §3553(a) factors and reasonably weighed them against reduction; also argued appeal timeliness (district court tolling contested)	Affirmed — court adequately considered §3553(a) factors and did not abuse discretion; appeal timely because post-judgment motion tolled the appeal period
Whether the district court abused discretion by giving limited weight to post-sentencing conduct	Burch: his educational/vocational progress warranted more weight	Government: court may consider but need not rely heavily on post-sentencing conduct absent reliable documentation	Affirmed — district court permissibly focused on offense seriousness and public protection over coursework

United States v. Anderson, 772 F.3d 662 (11th Cir. 2014) (standard of review for §3582(c)(2) legal conclusions)
United States v. Jules, 595 F.3d 1239 (11th Cir. 2010) (abuse-of-discretion review of a district court’s decision under §3582)
United States v. Bravo, 203 F.3d 778 (11th Cir. 2000) (two-step framework for §3582(c)(2) sentence reductions)
United States v. Williams, 557 F.3d 1254 (11th Cir. 2009) (requirement that §3553(a) factors be considered; post-sentencing conduct may be considered)
United States v. Clay, 483 F.3d 739 (11th Cir. 2007) (district court has discretion in weighing §3553(a) factors)
United States v. Glover, 686 F.3d 1203 (11th Cir. 2012) (post-judgment motions toll the time to appeal)