U.S. Court of Appeals for the Fifth Circuit, 2026

United States v. Walters

United States v. Walters
U.S. Court of Appeals for the Fifth Circuit · Decided May 27, 2026
United States v. Walters

Opinion

Case: 25-60203 Document: 93-1 Page: 1 Date Filed: 05/27/2026

United States Court of Appeals for the Fifth Circuit ____________ United States Court of Appeals Fifth Circuit No. 25-60203 Summary Calendar FILED ____________ May 27, 2026 Lyle W. Cayce United States of America, Clerk Plaintiff—Appellee, versus Wade Ashley Walters, Defendant—Appellant. ______________________________ Appeal from the United States District Court for the Southern District of Mississippi USDC No. 2:20-CR-26-1 ______________________________ Before Jones, Duncan, and Douglas, Circuit Judges.

Per Curiam: * Wade Ashley Walters, federal prisoner # 21647-043, appeals the denial of his 18 U.S.C. § 3582(c)(2) motion to reduce his 216-month total sentence for conspiracy to commit healthcare fraud and conspiracy to commit money laundering. He contends that the district court erred in denying a sentence reduction under Amendment 821 to the Sentencing _____________________ * This opinion is not designated for publication. See 5th Cir. R. 47.5.

Case: 25-60203 Document: 93-1 Page: 2 Date Filed: 05/27/2026

No. 25-60203

Guidelines because (i) he was eligible for a sentence reduction under U.S.S.G. § 4C1.1; (ii) the district court was allowed to reduce his sentence to a term that was below the minimum of the amended guidelines range because received a sentence reduction based on substantial assistance; and (iii) the district court failed to apply the 18 U.S.C. § 3553(a) factors to determine whether a sentence reduction was warranted. We review de novo the district court’s determination that it was not authorized under the Guidelines to grant a reduction. United States v. Calton, 900 F.3d 706, 710 (5th Cir. 2018).

To receive a § 3582(c)(2) reduction, a defendant must have been sentenced “based on a sentencing range that has subsequently been lowered by the Sentencing Commission.” 18 U.S.C. § 3582(c)(2). “For a sentence to be ‘based on’ a lowered Guidelines range, the range must have at least played ‘a relevant part in the framework the sentencing judge used’ in imposing the sentence.” United States v. Lopez, 989 F.3d 327, 333 (5th Cir. 2021) (quoting Koons v. United States, 584 U.S. 700, 705 (2018)).

Our review indicates that, in granting a downward departure, the district court did not base Walters’s 216-month sentence on any of its alternative determinations of the guidelines range. Because the record indicates that these guidelines ranges were ultimately “scrapped,” Koons, 584 U.S. at 705, and did not play a relevant part in the final sentencing framework, see Lopez, 989 F.3d at 333, his sentence was not based on those ranges; accordingly, he is not eligible for a sentence reduction despite the range being lowered by Amendment 821. See 18 U.S.C. § 3582(c)(2).

AFFIRMED.

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