United States v. Sawyer, 225 F. Supp. 3d 1314

Background

In 2008 Reginald L. Sawyer was sentenced to 168 months: 108 months on grouped drug/firearm counts and a consecutive 60 months under 18 U.S.C. § 924(c). A §5K1.1/§3553(e) substantial‑assistance motion produced a six‑level downward departure from a 240‑month statutory mandatory minimum on the principal drug count.
After Sawyer’s sentence became final, the Sentencing Commission promulgated Amendment 782 (retroactive two‑level reduction to drug offense base levels) and Amendment 780 (adding §1B1.10(c), directing courts to ignore statutory mandatory minimums when computing amended guideline ranges for defendants who received below‑minimum sentences for substantial assistance).
The district court’s Retroactivity Screening Panel split on whether Amendment 780 overrides the statutory mandatory minimum and Eleventh Circuit precedent; the court certified the question for resolution.
The Eleventh Circuit precedent (e.g., Glover, Mills, Williams earlier Eleventh Circuit holdings) holds that a sentence that was based on a statutory mandatory minimum (even when later reduced for substantial assistance) is not “based on a sentencing range” subsequently lowered by the Commission and thus is ineligible for §3582(c)(2) relief.
The district court found Amendment 780 improperly attempts to override a statutory mandatory minimum and Eleventh Circuit precedent; it held Sawyer is ineligible for §3582(c)(2) relief. The court alternatively ruled that even if eligible, §3553(a) factors would not justify a reduction.

Issues

Issue	Plaintiff's Argument (Sawyer)	Defendant's Argument (Government)	Held
Whether a defendant who received a below‑mandatory minimum sentence via a §5K1.1/§3553(e) substantial‑assistance departure is eligible for §3582(c)(2) relief based on Amendment 782 when §1B1.10(c) directs ignoring statutory minimums	Amendment 780/§1B1.10(c) controls: recalculate amended guideline range without regard to statutory trumping rules, making Sawyer eligible for a reduction under Amend. 782	The sentence remained "based on" the statutory mandatory minimum; Eleventh Circuit precedent forecloses §3582(c)(2) relief; government deferred to court discretion but historically has sometimes conceded eligibility in other districts	Court held Sawyer not eligible: §1B1.10(c) cannot override a congressional statutory mandatory minimum and Glover/Mills control; sentence was based on the statutory minimum
If eligible, whether the §3553(a) factors warrant a reduction and extent of reduction	Sawyer seeks a reduction to reflect Amendment 782 and prior departure magnitude	Government deferred to court discretion on extent; argued sentencing factors may counsel against large reduction	Court alternatively held §3553(a) factors counseled against reduction: original 108‑month drug sentence (plus 60 months consecutive) adequately accounted for seriousness, deterrence, public safety, and disparity concerns

Key Cases Cited

United States v. Glover, 686 F.3d 1203 (11th Cir.) (retroactive guideline amendment does not lower a defendant’s sentencing range when original sentence was based on a statutory mandatory minimum)
United States v. Mills, 613 F.3d 1070 (11th Cir.) (same principle: statutory mandatory minimums mean sentence was not "based on a sentencing range" lowered by amendment)
United States v. Head, 178 F.3d 1205 (11th Cir. 1999) (when guideline range is below statutory mandatory minimum, the mandatory minimum is the baseline for calculating a substantial‑assistance departure)
Dillon v. United States, 560 U.S. 817 (Sup. Ct.) (policy statement §1B1.10 governs §3582(c)(2) proceedings and is binding on courts)
United States v. Williams, 808 F.3d 253 (4th Cir.) (panel applied §1B1.10(c) to permit §3582(c)(2) relief for a substantial‑assistance cooperator; includes Chief Judge Traxler’s dissent questioning the Commission’s authority to override statutes)
United States v. Eggersdorf, 126 F.3d 1318 (11th Cir.) (statutes control where they conflict with the Guidelines)