United States v. Santana-Villanueva, 144 F. Supp. 3d 149

Santana‑Villanueva was indicted for conspiracy to distribute 5+ kg of cocaine and marijuana; pled guilty to a lesser count (conspiracy to distribute >500 g cocaine and marijuana).
In his plea agreement he admitted accountability for at least 5 but less than 15 kg of cocaine and agreed that 96 months (8 years) was the appropriate sentence.
The plea agreement included a conditional clause: if the court rejected the agreed 96‑month term, sentencing would proceed under 18 U.S.C. § 3553 and consideration of the Guidelines.
The Sentencing Commission adopted Amendment 782 (and made it retroactive via Amendment 788), lowering many drug‑offense Guidelines ranges, and Santana‑Villanueva moved under 18 U.S.C. § 3582(c)(2) for a reduced sentence.
The government did not oppose the motion but provided little substantive legal analysis.
The district court denied the § 3582(c)(2) motion, holding Santana‑Villanueva is ineligible because his sentence was not "based on" a Guidelines range.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Santana‑Villanueva is eligible for § 3582(c)(2) relief based on Amendment 782	Santana‑Villanueva seeks reduction because Amendment 782 lowered the Guidelines for his offense	He contends the agreed sentence should be treated as "based on" a Guidelines range for § 3582(c)(2) eligibility	Denied — not eligible because his sentence was not "based on" the Guidelines range
Whether a Rule 11(c)(1)(C) plea forecloses § 3582(c)(2) relief	(implicit) Freeman/Epps allow relief if sentence was based on Guidelines	Santana‑Villanueva relies on precedent permitting relief when the sentence rests on a Guidelines range	Court finds Epps distinguishable and relief unavailable because plea contemplated a negotiated 96‑month term independent of Guidelines
Role of sentencing transcript in assessing whether sentence was "based on" Guidelines	N/A	Argues there is no sentencing colloquy showing reliance on Guidelines	Court notes defendant did not identify any sentencing remarks tying the sentence to the Guidelines; absence supports ineligibility
Effect of government's lack of opposition	Government declined to oppose due to resources	Defendant benefited from unopposed posture	Court criticizes government's lack of analysis but proceeds to decide on the merits and denies relief

Dillon v. United States, 560 U.S. 817 (granting § 3582(c)(2) requires both eligibility and that a reduction is warranted)
Freeman v. United States, 131 S. Ct. 2685 (plea agreements do not automatically bar § 3582(c)(2) relief)
United States v. Epps, 707 F.3d 337 (D.C. Cir. 2013) (explains how to determine whether a sentence imposed pursuant to a Rule 11(c)(1)(C) plea is "based on" a Guidelines range)