United States v. Aponte-Guzman, No. 12-1180 (1st Cir. 2012)Annotate this Case
Appellant entered a guilty plea to conspiracy to possess with intent to distribute various controlled substances, including crack cocaine, and conspiracy to possess firearms in furtherance of a drug-trafficking crime. On July 27, 2010, the district court sentenced Appellant to a 150-month incarcerative term. On August 3, 2010, Congress enacted the Fair Sentencing Act of 2010 (FSA), which gave the Sentencing Commission emergency authority to lower the guideline penalties for crack cocaine offenses. The Commission promulgated the new guideline amendments, which ensured that the lowered guideline ranges would for the most part be available for retroactive application. In anticipation of the November 1, 2011 effective date, Appellant filed a motion for a sentence reduction. The district court declined to reduce the sentence "in the exercise of its discretion." The First Circuit Court of Appeals affirmed, holding that the catalogued factors plainly indicated that the court gave individualized consideration to Appellant's situation and had specific - and not unreasonable - grounds for denying a sentence reduction.