United States v. Williams, 2:20-cr-00171

In 2023, the U.S. Sentencing Commission adopted "Amendment 821," which retroactively reduced the criminal history "Status Points" used in Guidelines calculations for certain defendants.
Cashmeir T. Williams pleaded guilty in federal court to being a felon in possession of a firearm while he was on extended state supervision, resulting in eight criminal history points and a Guidelines range of 92–115 months.
Williams received a below-Guidelines sentence of 80 months in September 2022 and has already served nearly three years of that sentence.
After Amendment 821’s retroactive effect began in November 2023, Williams filed a motion to reduce his sentence based on the revised calculation of his criminal history, dropping him to six points and an amended range of 78–97 months.
The U.S. Probation Office confirmed Williams was eligible for the reduction; the government did not oppose it.
The court determined an additional reduction was appropriate and reduced Williams’s term of imprisonment to 78 months.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Williams is eligible for sentence reduction under Amendment 821.	Williams’ status points qualify him for the reduction.	Amendment 821 applies, lowering his criminal history and new Guidelines range.	Court held Williams is eligible for a reduction.
Whether the § 3553(a) factors warrant a further reduction.	No express opposition; original argument favored within-Guidelines sentence.	§ 3553(a) and new Sentencing Guidelines warrant additional decrease.	§ 3553(a) factors support reduction to 78 months.
Whether reduction must be to at least the minimum of the amended Guidelines range.	N/A	Sentence may not go below new minimum.	Court set new term at 78 months, the range minimum.
Need for hearing or re-sentencing during modification under 18 U.S.C. § 3582(c)(2)	N/A	No hearing required per existing precedent.	Court found no hearing necessary.

United States v. Blake, 986 F.3d 756 (7th Cir. 2021) (explains that a sentence reduction under § 3582(c)(2) is not a resentencing and does not require a resentencing hearing)
United States v. Hald, 8 F.4th 932 (10th Cir. 2021) (reiterates the procedure for § 3582(c)(2) motions concerning sentence reductions)