United States v. Beckham, No. 15-2592 (6th Cir. 2016)
Annotate this CaseIn 2009, Beckham pleaded guilty without a plea agreement to charges of conspiring to distribute more than 500 grams of cocaine and an unspecified amount of ecstasy. The presentence report relied on the 2009 version of the Sentencing Guidelines. The district court determined that Beckham’s total offense level was 30 and that his criminal-history category was six, resulting in a Guidelines range of 168–210 months’ imprisonment. The court departed downward under U.S.S.G. 4A1.3 to a criminal-history category of four, finding that the Guidelines overstated the severity of Beckham’s criminal past, and sentenced Beckham to 135 months’ imprisonment. In 2014, the Sentencing Commission retroactively lowered the base-offense level for most drug crimes, including Beckham’s. Beckham moved to modify his sentence under 18 U.S.C. 3582(c)(2). Meanwhile, the Commission had issued Amendment 759, which “preclude[s] district courts from reapplying any departure or variance in a sentence reduction” and forbids courts from reducing a sentence below an amended Guidelines range, with one narrow exception. The Sixth Circuit affirmed denial of the motion. Because Beckham’s current sentence is below the low end of his amended Guidelines range (140 months), he is ineligible for a further reduction.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.