United States v. Sedrick Lawson
686 F.3d 1317
| 11th Cir. | 2012Background
- Lawson was convicted of distributing crack cocaine in violation of 21 U.S.C. § 841(a)(1), (b)(1)(C).
- A probation officer assigned a base offense level of 20 under § 2D1.1(a)(3).
- Because Lawson was a career offender, the court applied § 4B1.1(b), resulting in a total offense level of 34 and a criminal history category of VI.
- The applicable guideline range became 262 to 327 months, and Lawson was sentenced to 262 months.
- In November 2011, Lawson moved for a sentence reduction under § 3582(c)(2) based on Amendment 750; the district court denied.
- Moore governs the scope of relief under § 3582(c)(2) when a career-offender’s range is not lowered by the relevant amendment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Lawson is eligible for § 3582(c)(2) relief. | Lawson contends Freeman makes him eligible. | Moore controls; Amendment 750 did not lower his range. | Denied; relief not available. |
Key Cases Cited
- United States v. Moore, 541 F.3d 1323 (11th Cir. 2008) (career-offender baseline; amendments do not alter range when not affecting range)
- United States v. Kaley, 579 F.3d 1246 (11th Cir. 2009) (binding precedent; panel decision not overruled by later Supreme Court rulings unless clearly on point)