United States v. Mercado-Moreno, No. 15-10545 (9th Cir. 2017)
Annotate this CaseWhen deciding an 18 U.S.C. 3582(c)(2) motion, a district court may supplement the original sentencing court's quantity findings only when supplemental findings are necessary to determine the defendant's eligibility for a sentence reduction in light of a retroactive Guidelines amendment. However, the district court may not make supplemental findings that are inconsistent with the findings made by the original sentencing court. A district court has broad discretion in how to adjudicate section 3582(c)(2) proceedings, including whether to hold a hearing when making supplemental findings of drug quantity. In this case, the Ninth Circuit affirmed the district court's denial of defendant's motion for a sentence reduction under section 3582(c)(2), based on Guidelines Amendment 782, which raised the threshold amount of methamphetamine to trigger the maximum base offense level from 1.5 kilograms to 4.5 kilograms. The district court did not abuse its discretion in concluding, without a hearing, that defendant was ineligible for a sentence reduction under section 3582(c)(2) because Amendment 782 did not lower his applicable guideline range.
Court Description: Criminal Law The panel affirmed the district court’s denial of a motion for reduction of sentence under 18 U.S.C. § 3582(c)(2) in light of retroactive Sentencing Guidelines Amendment 782, which raised from 1.5 to 4.5 kilograms the quantity of actual methamphetamine required to trigger the maximum base offense level. The panel held that a district court in § 3582(c)(2) proceedings may make supplemental findings of drug quantity if they are necessary to determine the defendant’s eligibility for a sentence reduction in light of a retroactive Guidelines amendment, but that in doing so, the district court may not make supplemental findings that are inconsistent with the findings made by the original sentencing court.
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