United States v. William Mahan
705 F. App'x 547
9th Cir.2017Background
- Mahan was sentenced in 2008 to 120 months for firearm and drug convictions (the 120‑month term at issue) plus a consecutive mandatory 60 months under § 924(c), total 180 months.
- Original Guidelines calculation produced an advisory range of 140–175 months; the district court granted a downward variance to 120 months to account in part for ~20 months Mahan spent in state custody before federal resolution and his rehabilitation.
- Sentencing Commission Amendment 782 (2014) reduced Mahan’s drug offense base level, producing a new guidelines range of 120–150 months.
- Mahan moved under 18 U.S.C. § 3582(c)(2) for a sentence reduction to 100 months so the court would again credit the ~20 months he served in state custody.
- The district court denied the motion, relying on U.S.S.G. § 1B1.10(b)(2)(B) to conclude it could not reduce a term below the amended guideline range.
- The Ninth Circuit vacated and remanded, holding (in light of United States v. Brito) that § 1B1.10(b)(2)(B) does not bar a court from crediting state time served as part of a defendant’s "term of imprisonment," and directing the district court to exercise its discretion consistent with that view.
Issues
| Issue | Plaintiff's Argument (Mahan) | Defendant's Argument (Gov't / District Ct.) | Held |
|---|---|---|---|
| Whether § 1B1.10(b)(2)(B) prohibits reducing a sentence below the amended guideline range to credit prior state custody | Court may reduce below the amended range to credit ~20 months state time as part of the term of imprisonment (seek 100 months) | § 1B1.10(b)(2)(B) forbids reducing a term to less than the amended guideline range | The Ninth Circuit held § 1B1.10(b)(2)(B) does not preclude crediting state time; vacated and remanded for district court to exercise discretion per Brito |
| Whether the district court abused its discretion in denying the § 3582(c)(2) reduction | District court should consider prior state custody and rehabilitation in exercising discretion and may grant reduction | District court lawfully denied reduction based on § 1B1.10(b)(2)(B) interpretation | Court reviewed de novo the legal question (crediting time) and concluded the district court misapplied the law; remand for discretionary decision |
| Standard of review for denial of § 3582(c)(2) motion | N/A (contextual) | N/A | Denial reviewed for abuse of discretion; question of law (crediting time) reviewed de novo |
| Whether precedent requires a particular outcome on remand | N/A | N/A | Court directed remand to apply Brito; outcome depends on district court’s discretionary exercise after correct legal framing |
Key Cases Cited
- United States v. Chaney, 581 F.3d 1123 (9th Cir. 2009) (standard of review for § 3582(c)(2) sentence reduction)
- United States v. Williams, 636 F.3d 1229 (9th Cir. 2011) (deference to within‑Guidelines sentences)
- United States v. Peters, 470 F.3d 907 (9th Cir. 2006) (question of law regarding crediting time reviewed de novo)
- United States v. Brito, 868 F.3d 875 (9th Cir. 2017) (holding § 1B1.10(b)(2)(B) does not bar crediting state custody as part of "term of imprisonment")