United States v. Taylor, 4:21-cr-40052

Defendant Dustin R. Mezo pled guilty to conspiracy to distribute methamphetamine and was sentenced to 132 months in prison.
At sentencing, his criminal conduct involved over 1,219 grams of methamphetamine, resulting in a base offense level of 30, with a 3-point reduction for acceptance of responsibility (final level: 27).
Mezo had 10 criminal history points, but none were due to 'status points,' placing him in Criminal History Category V.
Mezo moved for a reduced sentence under 18 U.S.C. § 3582(c)(2) and U.S.S.G. Amendment 821, which allows retroactive reductions based on certain changes to criminal history calculations.
His appointed counsel believed Mezo was not eligible for a reduction and moved to withdraw; the government agreed, and Mezo did not oppose.
The court considered the request and counsel's withdrawal motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eligibility for sentence reduction under § 3582(c)(2) and Amendment 821	Mezo was not eligible	Amendment 821 changes should apply	Mezo not eligible; amendment did not lower range
Applicability of Amendment 821 Part A (status points)	No status points applied	Amendment covers broad criminal history	Amendment 821 Part A inapplicable to Mezo
Applicability of Amendment 821 Part B (no criminal history)	Mezo had criminal history	Should cover low criminal history cases	Amendment 821 Part B inapplicable to Mezo
Counsel's Motion to Withdraw	No objection to withdrawal	N/A	Motion granted; counsel terminated

Anders v. California, 386 U.S. 738 (1967) (standard for counsel seeking to withdraw when no meritorious grounds for appeal are found)