United States v. Stith & Brantley, 717 F.3d 287

Brantley and Stith challenged two 2011 reduction orders under 18 U.S.C. § 3582(c)(2) after retroactive crack-cocaine amendments.
District court reduced their sentences but held § 1B1.10(b)(2)(A) prevents reductions below the amended ranges, and denied further 4A1.3 departures.
Amended guideline ranges: Brantley 110–137 months; Stith 100–125 months.
Retroactive amendments were enacted by U.S.S.G. app. C, amend. 759 (2011) to align with Fair Sentencing Act changes.
Amendment 759 narrowed the 1B1.10(b)(2)(B) exception and clarified limitations on departures or variances in reductions.
Brantley and Stith appealed, arguing § 1B1.10(b)(2)(A) is invalid or, alternatively, that § 4A1.3 departures are still permitted in reductions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is § 1B1.10(b)(2)(A) a valid binding rule for § 3582(c)(2) reductions?	Brantley and Stith—§ 1B1.10(b)(2)(A) exceeds Commission authority.	District court—§ 1B1.10(b)(2)(A) binds courts; lawful.	Yes; § 1B1.10(b)(2)(A) binds district courts.
Does § 1B1.10(b)(2)(A) allow 4A1.3 departures during reductions?	§ 4A1.3 departures may be incorporated into the amended range.	§ 1B1.10(b)(2)(A) separately limits reduction, excluding prior 4A1.3 departures.	No; amendments do not incorporate prior 4A1.3 departures into the amended range.

United States v. Savoy, 567 F.3d 71 (2d Cir. 2009) (guidelines interpretation; de novo review of statute and guidelines)
United States v. Rivera, 662 F.3d 166 (2d Cir. 2011) (departures and application of guidelines terminology)
United States v. Awadallah, 349 F.3d 42 (2d Cir. 2003) (constitutional interpretation of guidelines provisions)
Dillon v. United States, 130 S. Ct. 2683 (2010) (Supreme Court on Commission authority and range adjustments)
United States v. Munn, 595 F.3d 183 (4th Cir. 2010) (interpretation of application of § 1B1.10 before amendments)
United States v. McGee, 553 F.3d 225 (2d Cir. 2009) (precedent on § 1B1.10 and reductions)