United States v. Jones
United States v. Jones
Opinion of the Court
Defendant Aaron Patrick Jones is presently serving a sentence of 120 months *169imprisonment, followed by 60 months of supervised release, after having pled guilty to one count of Conspiracy to Distribute and Possess With Intent to Distribute 5 Kilograms or More of Cocaine and 280 Grams or More of Cocaine Base, in violation of
Defendant's Motion relies upon the application of United States Sentencing Guidelines ("Guidelines") Amendment 782, which lowered the base offense levels for most drug offenses, and Amendment 788, which allowed the retroactive application of Amendment 782. In determining whether a sentence reduction is warranted under
The Court begins by considering whether Defendant is eligible for a sentence reduction under
Accordingly, a defendant is eligible for a reduction under § 3582(c) if and only if (1) the defendant's term of imprisonment was based on a sentencing range that has subsequently been lowered by a retroactive amendment to the Guidelines, (2) the retroactive amendment to the Guidelines has the effect of lowering the defendant's applicable guideline range, and (3) the reduction does not result in a sentence that is less than the minimum of the amended guideline range, unless the defendant contributed substantial assistance to authorities. See U.S.S.G. § 1B1.10 ; Berry ,
The Court begins its analysis of whether Defendant is eligible for a sentence reduction under § 3582(c) by looking to whether his prison sentence was "based on" a Guidelines range that has subsequently *170been lowered.
In this case, however, Mr. Jones' mandatory minimum sentence of 120 months fell within his Guidelines range of 120 to 135 months. Probation Memo, ECF No. 233. And when the mandatory minimum falls within or below the defendant's Guidelines range, the sentencing guidelines require the district judge to impose a sentence equal to or greater than the mandatory minimum but "within the applicable guideline range." U.S.S.G. § 5G1.1(c). The sentencing judge in this case was accordingly required to consider Mr. Jones' Guidelines range (120-135 months) as part of her sentencing framework. Accordingly, Mr. Jones' sentence was "based on" the Guidelines, as they played a relevant part in the sentencing judge's framework. See Valle ,
The second part of the inquiry into whether Defendant is eligible for a sentence reduction under § 3582(c) looks to whether the retroactive amendment to the Guidelines had the effect of lowering Defendant's Guidelines range. When Mr. Jones was sentenced, his Guidelines range was 120 to 135 months' imprisonment. Probation Memo, ECF No. 233. Absent his mandatory minimum, the amendment would have lowered his range to 87-108 months.
The third and final analysis looks to whether Defendant's proposed sentence reduction would result in a sentence that is less than the minimum of the amended guidelines. See U.S.S.G. § 1B1.10(b)(2)(A) ("the court shall not reduce the defendant's term of imprisonment... to a term that is less than the minimum of the amended guideline range"). Here, the minimum of the amended guidelines is 120 months. Probation Memo, ECF No. 233. Mr. Jones, however, asks the Court to reduce his sentence to 97 to 108 months. Petitioner's Mot. For a Reduction of his Sentence, ECF No. 217, at 3. Mr. Jones is ineligible for a reduced term of imprisonment under § 3582(c)(2) because the Court is not authorized to reduce his term of imprisonment below 120 months. U.S.S.G. § 1B1.10(b)(2)(A). Because Mr. Jones is not eligible for a reduction under step one of the inquiry, which looks to § 3582(c)(2), the Court need not engage in step two, which involves analyzing the factors set out in 3553(a).
Because this Order references documents that are not publicly available, it is being sealed.
As a preliminary matter, Defendant was sentenced in accordance with a written plea agreement executed pursuant to F.R.C.P. Rule 11(c)(1)(C). See Plea Agreement as to Aaron Patrick Jones, ECF No. 63. The fact that Defendant's sentence was based on a Rule 11(c)(1)(C) plea agreement, however, does not categorically bar a § 3582(c) motion as his sentence could still have been "based on" the Guidelines' sentencing range. Hughes v. U.S. , No. 17-155, --- U.S. ----,
Case-law data current through December 31, 2025. Source: CourtListener bulk data.