United States v. Sims
1:11-cr-00037
| W.D. Mich. | Aug 21, 2025Background:
- Defendant Andrea Marie Mast pleaded guilty to sexual exploitation of children under 18 U.S.C. § 2251(a) and (e).
- She was sentenced to 360 months’ imprisonment followed by a life term of supervised release.
- In August 2023, the United States Sentencing Commission proposed Amendment 821 to the Sentencing Guidelines, which became effective November 1, 2023 after Congressional inaction.
- Amendment 821 allows certain defendants to seek sentence reductions if their applicable guideline ranges are lowered due to the amendment's retroactive effect.
- Mast filed a pro se motion for sentence reduction under 18 U.S.C. § 3582(c)(2), arguing that Amendment 821 warranted a reduction in her sentence.
- The Probation Office determined Mast was not eligible because she received criminal history points and did not receive status points under the applicable guideline provisions.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument (Mast) | Held |
|---|---|---|---|
| Whether Amendment 821 applies retroactively to reduce Mast's sentence under 18 U.S.C. § 3582(c)(2) | Mast not eligible due to criminal history points and no status points | Amendment 821 applies and justifies a sentence reduction | Denied; Mast is not eligible for a reduction under Amendment 821 |
Key Cases Cited
- United States v. Jones, 980 F.3d 1098 (6th Cir. 2020) (explains the two-step inquiry required for sentence reductions under § 3582(c))
- Dillon v. United States, 560 U.S. 817 (2010) (sets the framework for evaluating sentence reductions under amended sentencing guidelines)