United States v. Spencer Peters, 843 F.3d 572

Background

Spencer Peters was convicted of conspiracy to distribute cocaine base (crack) and a related firearms conspiracy; sentenced in 2009 to 480 months after the court applied the maximum Guidelines base offense level based on attributable drug quantity.
Original PSR and district court findings attributed at least 4.5 kg (and the government estimated ~150 kg) of cocaine base to the conspiracy; Peters got leadership and firearms enhancements.
The Sentencing Commission’s Amendment 782 (retroactive) raised the cocaine-base threshold for the maximum base offense level from 8.4 kg to 25.2 kg, potentially changing eligibility for § 3582(c)(2) reductions.
Peters moved under 18 U.S.C. § 3582(c)(2) seeking a reduction under Amendment 782; the district court denied the motion as ineligible, concluding quantity rendered him ineligible.
On appeal Peters argued the court failed to explain its eligibility finding and that attributing ≥25.2 kg to him was clearly erroneous. The Fourth Circuit affirmed.

Issues

Issue	Peters' Argument	Government / District Court Argument	Held
Whether district court had to make a more detailed, individualized explanation when denying § 3582(c)(2) relief based on drug quantity	District court failed to state specific factual findings showing Peters was accountable for ≥25.2 kg and did not define relevant conduct scope	§ 3582(c)(2) proceedings are limited; existing record, PSR, and prior findings suffice and courts may rely on prior record without ritualistic restatement	Court held no greater specificity required; denial stating ineligibility plus reliance on PSR/record was adequate
Whether a district court may make supplemental drug-quantity findings in § 3582(c)(2) proceedings	(Implicit) Peters opposed reattribution beyond original findings without explicit findings	District court may supplement earlier quantity findings so long as they do not contradict prior findings and are supported by the record	Court held district courts may make additional, non-contradictory quantity findings supported by the record
Whether the attributable drug quantity finding (≥25.2 kg) was clearly erroneous	Peters argued the record did not support accountability for ≥25.2 kg, especially excluding periods he was incarcerated	District court relied on leadership role, PSR, witness testimony of weekly 1–2 kg imports, foreseeable conduct of co-conspirators	Court held finding was not clearly erroneous given Peters’ leadership role, ongoing involvement, and corroborated evidence
Whether Amendment 782 changed Peters’ Guidelines range and thus triggered eligibility for relief	Peters claimed he might fall below the new 25.2 kg threshold and thus be eligible	Government argued Peters remained above the threshold so Amendment 782 did not alter his applicable base level	Court held Peters was accountable for ≥25.2 kg so Amendment 782 did not lower his Guidelines range and § 3582(c)(2) relief was unavailable

Key Cases Cited

Dillon v. United States, 560 U.S. 817 (explaining § 3582(c)(2) permits only limited adjustments, not plenary resentencing)
United States v. Legree, 205 F.3d 724 (4th Cir.) (district courts need not ritualistically restate prior findings in § 3582(c)(2) proceedings)
United States v. Smalls, 720 F.3d 193 (4th Cir.) (presumption that district court considered § 3553(a) factors in § 3582(c)(2) rulings; limited explanation may suffice)
United States v. Mann, 709 F.3d 301 (4th Cir.) (review standard; recognizes sister circuits allowing supplemental findings)
United States v. Hall, 600 F.3d 872 (7th Cir.) (district court may make new, record-supported findings consistent with original sentencing)
United States v. Hamilton, 715 F.3d 328 (11th Cir.) (district court may specify quantities within ranges previously found)
United States v. Wyche, 741 F.3d 1284 (D.C. Cir.) (if original sentencing court failed to calculate specific quantity, resentencing court may need to make its own finding)