United States v. Padilla-Diaz, No. 15-30279 (9th Cir. 2017)
Annotate this CaseThe Ninth Circuit affirmed the denial of defendants' motions for sentence reductions under United States Sentencing Guidelines Amendment 782 and 18 U.S.C. 3582(c)(2). The panel held that USSG 1B1.10(b)(2)(A) does not impermissibly conflict with 28 U.S.C. 991(b) and defendants have not shown that section 1B1.10(b)(2)(A) violates equal protection or due process. Under section 1B1.10(b)(2)(A), defendants who originally had lower sentences may be awarded the same sentences in section 3582(c)(2) proceedings as offenders who originally had higher sentences. Sentences that were initially tailored to avoid unwarranted disparities and to account for individualized circumstances will now converge at the low end of the amended guideline range. The panel explained that this anomalous result did not create an irreconcilable conflict with section 991(b). Furthermore, while section 1B1.10(b)(2)(A) will sometimes produce unequal and arguably unfair results, defendants have not shown that it fails rational basis review. As to due process, defendants' failure to receive a benefit from Amendment 782 was not a result of a retroactive deprivation of a pre-existing benefit. Rather, it was the result of a prospective grant of a limited benefit.
Court Description: Criminal Law. The panel affirmed the district court’s denials of three defendants’ motions for sentence reductions under United States Sentencing Guidelines Amendment 782 and 18 U.S.C. § 3582(c)(2). Each defendant was denied a reduction based on an application of the Sentencing Commission’s Policy Statement § 1B1.10(b)(2)(A), which prohibits courts from reducing a defendant’s “term of imprisonment” to “less than the minimum of the amended guideline range,” absent circumstances not present here. The panel rejected the defendants’ contention that § 1B1.10(b)(2)(A) conflicts with 28 U.S.C. § 991(b) by nullifying departures and variances from the guideline range that were necessary to meet the statutory mandates of achieving a sentence sufficient but not greater than necessary under 18 U.S.C. § 3553(a). The panel held that the anomalous result – that sentences initially tailored to avoid unwarranted disparities and to account for individualized circumstances will now converge at the low end of the guideline range – does not create an irreconcilable conflict with § 991(b). The panel explained that § 991(b) is a general statement of the Commission’s goals, and that as acts of lenity, § 3582(c)(2) reductions are not constrained by the 4 UNITED STATES V. PADILLA-DIAZ general policies underlying initial sentencing or even plenary resentencing proceedings. Rejecting the defendants’ contention that § 1B1.10(b)(2)(A) violates the equal protection component of the Fifth Amendment by irrationally denying sentence reductions to offenders who received lower sentences while granting them to those who originally received higher sentences, the panel held that the defendants have not shown that § 1B1.10(b)(2)(A) fails rational basis review. The panel rejected the contention by two defendants that applying the current version of § 1B1.10 to them violates due process because they entered into their plea agreements prior to its amendment. The panel explained that the defendants’ failure to receive a benefit from Amendment 782, which was promulgated after their pleas and is governed by limitations on its sentence reductions, is not the result of a retroactive deprivation of a pre-existing benefit, but rather the result of a prospective grant of a limited benefit.
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