Hughes v. United States

Hughes, indicted on drug and gun charges, negotiated a Type-C plea agreement, which stipulated that Hughes would receive a sentence of 180 months but did not refer to a particular Guidelines range. The district court sentenced him to 180 months, calculating Hughes’ Guidelines range as 188-235 months and finding that the sentence was in accordance with the Guidelines and other factors it was required to consider. Weeks later, the Sentencing Commission adopted and made retroactive an amendment that had the effect of reducing Hughes’ sentencing range to 151-188 months. The Eleventh Circuit affirmed the denial of Hughes’ motion for a reduced sentence under 18 U.S.C. 3582(c)(2). The Supreme Court reversed, resolving a split among the circuits. A sentence imposed pursuant to a Type-C agreement is “based on” a Guidelines range if that range was part of the framework the district court relied on to impose the sentence or accept the agreement. A district court imposes a sentence that is “based on” a Guidelines range for purposes of section 3582(c)(2) if the range was a basis for the court’s exercise of discretion. District courts are required to calculate and consider a defendant’s Guidelines range in every case. The Guidelines prohibit district courts from accepting Type-C agreements without first evaluating the recommended sentence in light of the defendant’s Guidelines range. View "Hughes v. United States" on Justia Law