United States v. Wanda Solomon, 665 F. App'x 158

Wanda Solomon led a long-running cocaine/crack distribution conspiracy in western Pennsylvania, involving multiple family members and at least one minor.
She pled guilty to conspiracy counts and, at 2007 sentencing, was held accountable for 5–15 kg of cocaine; base offense level 32 was raised for role and involvement of a minor, yielding an adjusted offense level 35 and a Guidelines range of 210–262 months.
The District Court sentenced Solomon to 240 months, relying on § 3553(a) factors and emphasizing her leadership role, use of minors, continued operation after an associated murder, and criminal history.
After the Sentencing Commission’s retroactive amendment lowering certain drug offense base levels, Solomon moved under § 3582(c)(2) for a discretionary reduction to 168 months (new Guidelines range 168–210 months), citing post‑sentencing rehabilitative conduct.
The District Court found Solomon eligible but declined to reduce the sentence, concluding its original § 3553(a) balancing and the severity of her conduct (leadership, minors, continued operation post‑murder) warranted keeping the 240‑month term.
Solomon appealed; the Third Circuit reviews § 3582(c)(2) denials for abuse of discretion and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the District Court abused its discretion in denying a § 3582(c)(2) sentence reduction after retroactive Guidelines amendment	Solomon: amendment and post‑sentencing rehabilitation justify reducing her sentence to the lower Guidelines range	Government/District Court: although eligible, seriousness of offense, leadership role, use of minors, continued operation after a related murder, and prior history support denying reduction	Denial affirmed — Court reasonably weighed § 3553(a) factors and did not abuse discretion (discretionary reduction not required)
Whether the District Court legally erred by stating the original sentence "was not ultimately based on" the Guidelines	Solomon: statement reflects a legal error that taints the § 3582(c)(2) analysis	District Court: statement meant that Guidelines were advisory and the original sentence rested on a § 3553(a) evaluation; same factors were re‑considered in the reduction motion	No legal error — statement contextual; court applied § 3553(a) in denying reduction

United States v. Styer, 573 F.3d 151 (3d Cir. 2009) (Third Circuit reviews § 3582(c)(2) denials for abuse of discretion and affords deference to district courts’ § 3553(a) balancing)