United States v. Ryan Powers
670 F. App'x 855
| 5th Cir. | 2016Background
- Ryan Powers, federal prisoner, was sentenced to 168 months for conspiracy to possess with intent to distribute >5 kg cocaine.
- He pleaded guilty under Federal Rule of Criminal Procedure 11(c)(1)(C), which set the agreed sentence.
- Powers moved under 18 U.S.C. § 3582(c)(2) for a sentence reduction based on Amendment 782 to the Sentencing Guidelines (lowering drug-table base offense levels).
- The district court denied the § 3582(c)(2) motion, finding Powers ineligible because his sentence was imposed pursuant to an 11(c)(1)(C) plea agreement that did not rely on a particular Guidelines range.
- Powers appealed, arguing (citing Freeman) that his 11(c)(1)(C) sentence could be considered "based on" a Guidelines range and thus eligible for reduction.
- The Fifth Circuit affirmed, concluding the plea agreement did not employ a particular Guidelines range to establish the agreed term, so § 3582(c)(2) relief was unavailable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a sentence imposed under an 11(c)(1)(C) plea is eligible for reduction under § 3582(c)(2) after Amendment 782 | Freeman allows an 11(c)(1)(C) defendant to qualify if the agreement is "based on" a Guidelines range; Powers contends his sentence qualifies | The plea did not specify or employ a particular Guidelines range to set the term, so it was not "based on" a subsequently lowered range | Denied — plea did not employ a particular Guidelines range; § 3582(c)(2) reduction unavailable |
| Whether the court should consider alternative ineligibility (career-offender status) | — | Government alternatively argued Powers’ career-offender status made him ineligible | Not reached — appellate court resolved ineligibility on the 11(c)(1)(C) grounds |
Key Cases Cited
- Freeman v. United States, 564 U.S. 522 (2011) (explains when an 11(c)(1)(C) agreement is "based on" a Guidelines range for § 3582(c)(2) eligibility)
- United States v. Benitez, 822 F.3d 807 (5th Cir. 2016) (applies Freeman to hold an 11(c)(1)(C) sentence not tied to a Guidelines range is ineligible for § 3582(c)(2) relief)