United States v. Tatis
669 F. App'x 606
| 2d Cir. | 2016Background
- Raul Tatis, serving a 121-month sentence for heroin trafficking, moved under 18 U.S.C. § 3582(c)(2) for a sentence reduction based on Amendments 782 and 788 to the Sentencing Guidelines which lowered base offense levels for most drug offenses.
- The Sentencing Commission’s amendments made Tatis eligible for a reduced range of 87–108 months.
- The district court denied Tatis’s § 3582(c)(2) motion after considering the applicable Guidelines policy statement, the § 3553(a) factors, and Tatis’s post-sentencing prison disciplinary history.
- Tatis appealed pro se the district court’s denial of a sentence reduction.
- The Second Circuit reviewed the denial for abuse of discretion and affirmed, finding the district court provided sufficient reasons and did not err in its assessment of the § 3553(a) factors or reliance on disciplinary infractions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Tatis is eligible for a § 3582(c)(2) reduction based on Amendments 782/788 | Tatis argued the guideline amendment lowered his applicable range making him eligible | Government conceded eligibility for a reduction to 87–108 months | Eligible for reduction but eligibility alone does not require relief |
| Whether the district court abused its discretion by denying a reduction | Tatis argued the court should have granted the reduction despite disciplinary infractions | Court argued it properly exercised discretion after weighing § 3553(a) factors and safety concerns | No abuse of discretion; denial affirmed |
| Whether the district court gave adequate reasons for denial | Tatis argued the district court failed to provide sufficient explanation | Court cited Tatis’s disciplinary record and articulated § 3553(a) consideration | Explanation was minimally sufficient for review |
| Whether post-sentencing conduct may justify denial | Tatis contended his conduct did not warrant denial | Government and district court relied on disciplinary infractions as relevant post-sentencing conduct | Post-sentencing conduct is a permissible and sufficient basis for denial |
Key Cases Cited
- United States v. Borden, 564 F.3d 100 (2d Cir. 2009) (standards for § 3582(c)(2) eligibility and abuse-of-discretion review)
- Dillon v. United States, 560 U.S. 817 (2010) (district court discretion in § 3582(c)(2) reductions and required considerations)
- United States v. Christie, 736 F.3d 191 (2d Cir. 2013) (district court must state minimal reasons for § 3582(c)(2) decisions)
- United States v. Wilson, 716 F.3d 50 (2d Cir. 2013) (public safety and post-sentencing conduct are relevant to reduction decisions)
- United States v. Rios, 765 F.3d 133 (2d Cir. 2014) (abuse of discretion standard for § 3582(c)(2) denials)
- United States v. Figueroa, 714 F.3d 757 (2d Cir. 2013) (affirming denial where post-sentencing conduct and § 3553(a) factors weighed against reduction)