United States v. Williams, 675 F. App'x 59

Ralston Williams was convicted of multiple drug offenses in 2012 and originally sentenced at the bottom of a Guidelines range to 168 months.
Amendment 782 (2014) reduced base offense levels for many drug offenses and made reductions retroactive under 18 U.S.C. § 3582(c)(2); Williams’s Guidelines range decreased to 135–168 months.
The district court sua sponte reduced Williams’s sentence to 152 months after trial counsel failed to file a § 3582(c)(2) motion; the government had not opposed a reduction within the new range and noted Williams had no disciplinary tickets.
The district court explained the reduction by citing the seriousness of Williams’s conduct, his lack of remorse at original sentencing, and a perceived significant risk of re-offending (language partly quoted from a sealed document).
Williams sought further reduction to 135 months and raised three main challenges on appeal: inadequate explanation, failure to consider post-sentencing (prison) conduct, and reliance on lack of remorse without notice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Adequacy of explanation for § 3582(c)(2) reduction	Williams: district court failed to adequately explain why it reduced sentence only to 152 months rather than to bottom of new range	Government: district court provided sufficient—albeit brief—reasons (dangerousness, lack of remorse, re-offense risk) and § 3582(c)(2) requires a minimal statement only	Affirmed — brief reasons were sufficient for meaningful appellate review under Christie
Consideration of post-sentencing prison conduct	Williams: court did not explicitly consider his clean disciplinary record in prison	Government: record (PSR Addendum, government letter) informed court and the sentence was reduced, so court presumptively considered factors	Affirmed — no abuse of discretion; presumption that judge considered statutory factors
Reliance on lack of remorse without notice	Williams: should have been given notice/opportunity to respond before court relied on lack of remorse	Government: lack of remorse was not new information; it was addressed at original sentencing, so no additional notice required	Affirmed — lack of remorse is a permissible § 3553(a) factor; Williams had prior notice from original sentencing

United States v. Christie, 736 F.3d 191 (2d Cir. 2013) (§ 3582(c)(2) reductions require only a minimal statement of reasons)
United States v. Figueroa, 714 F.3d 757 (2d Cir. 2013) (standard of review: abuse of discretion for § 3582(c)(2) decisions)
United States v. Fernandez, 443 F.3d 19 (2d Cir. 2006) (presumption that sentencing judge considered statutory factors)
United States v. Martinucci, 561 F.3d 533 (2d Cir. 2009) (lack of remorse is a legitimate § 3553(a) factor)
United States v. Jules, 595 F.3d 1239 (11th Cir. 2010) (notice required when court relies on new information in § 3582 proceeding)
United States v. Foster, 575 F.3d 861 (8th Cir. 2009) (same as Jules regarding notice for new information)
United States v. Mueller, 168 F.3d 186 (5th Cir. 1999) (same principle regarding notice when new information is relied upon)
Rita v. United States, 551 U.S. 338 (2007) (discusses appellate review and procedural requirements at sentencing)