United States v. Singleton

Case: 25-30657 Document: 65-1 Page: 1 Date Filed: 09/04/2026

United States Court of Appeals for the Fifth Circuit ____________ United States Court of Appeals Fifth Circuit

No. 25-30657 FILED Summary Calendar September 4, 2026 ____________ Lyle W. Cayce Clerk United States of America, Plaintiff—Appellee, versus Heath A. Singleton, Defendant—Appellant. ______________________________ Appeal from the United States District Court for the Eastern District of Louisiana USDC No. 2:93-CR-5-2 ______________________________ Before Stewart, Richman, and Higginson, Circuit Judges.

Per Curiam:* Heath A. Singleton, federal prisoner # 23478-034, appeals the district court’s denial of his 18 U.S.C. § 3582(c)(2) motion to reduce his life sentence for carjacking. Singleton based his motion on Part A of Amendment 821 to the Sentencing Guidelines.

Case: 25-30657 Document: 65-1 Page: 2 Date Filed: 09/04/2026

No. 25-30657

Singleton contends that the district court erred by failing to adequately consider his young age at the time of his offenses and his culpability relative to that of one of his codefendants. However, it is clear the district court reviewed Singleton’s motion, even if it did not explicitly address each of his arguments. See United States v. Batiste, 980 F.3d 466, 479 (5th Cir. 2020); United States v. Evans, 587 F.3d 667, 673 (5th Cir. 2009).

Additionally, Singleton asserts that the district court placed too much emphasis on his prison disciplinary history. While the district court mentioned that history, it was not the primary basis that the court relied on in denying his motion, and it was an appropriate factor for the district court to consider. See 18 U.S.C. § 3553(a)(1)); United States v. Smith, 595 F.3d 1322, 1323 (5th Cir. 2010).

Singleton also contends that the district court did not address the upward departure in his underlying sentence when addressing his motion for a sentence reduction. His arguments amount to a disagreement with the district court’s balancing of the § 3553(a) factors, which is insufficient to show any abuse of discretion. See Evans, 587 F.3d at 672-73.

Finally, Singleton’s asserts that the district court violated the holding in Tapia v. United States, 564 U.S. 319, 335 (2011), when relying upon his prison disciplinary history in denying his § 3582(c)(2) motion. However, Tapia is inapplicable, and Singleton has shown no error in this regard. See Tapia, 564 U.S. at 321-22; United States v. Chambliss, 948 F.3d 691, 693-94 (5th Cir. 2020).

Singleton has failed to demonstrate that the district court abused its discretion in denying his § 3582(c)(2) motion. See United States v. Calton, F.3d 706, 710 (5th Cir. 2018). Accordingly, the decision of the district court is AFFIRMED.