United States v. Walker, 2011 U.S. Dist. LEXIS 118850

Walker pled guilty under Rule 11(c)(1)(C) to possessing with intent to distribute crack cocaine and using, carrying, and possessing a firearm during a drug trafficking offense.
Plea agreement proposed a stipulated term of 78 months; court sentenced 60 months for 924(c) offense and 18 months consecutive for distribution charge.
Walker moved for a sentence reduction under 18 U.S.C. § 3582(c)(2) based on retroactive crack-cocaine guideline amendments.
The plea agreement does not show an intent to base the sentence on a particular Guidelines range subsequently lowered by the Sentencing Commission.
Supreme Court Freeman v. United States addressed whether Rule 11(c)(1)(C) sentences may be reduced under § 3582(c)(2) when guidelines were considered in imposing the sentence.
Court concludes Walker is ineligible for relief because the plea does not demonstrate intent to base the term on a subsequently lowered Guidelines range.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 3582(c)(2) relief applies to Rule 11(c)(1)(C) sentences.	Walker: eligible because sentence was based on a lowered range.	Government: not eligible since sentence was not based on a Guidelines range.	Ineligible under current interpretation.
Whether the plea agreement indicates intent to base sentence on a lower Guideline range.	Walker: intent implied by reliance on Guidelines.	Government: no explicit intent to base sentence on a lowered range.	No explicit intent shown; § 3582(c)(2) not applicable.
Impact of Freeman v. United States on Rule 11(c)(1)(C) reductions.	Freeman supports potential relief where guidelines informed the sentence.	Freeman does not support relief here due to lack of intent evidence.	Freeman bears on standard but not enough to grant relief.
Whether mere consideration of Guidelines in sentencing suffices for § 3582(c)(2) eligibility.	Consideration would make the sentence eligible.	Consideration alone is insufficient without intent to base on lowered range.	Not sufficient.

Freeman v. United States, 131 S. Ct. 2685 (2011) (held § 3582(c)(2) relief may apply if sentence was based on guidelines influenced by a lowered range, with caveats)