United States v. Negron, No. 15-1898 (1st Cir. 2016)
Annotate this CaseDefendant entered into a plea agreement pursuant to Fed. R. Crim. P. 11(c)(1)(C) (a “C-type plea agreement”), which binds the district court to a pre-agreed sentence if the court accepts the defendant’s plea. Under C-type plea agreements, a defendant is eligible for a sentence reduction based on a retroactive amendment to the United States Sentencing Guidelines only if the term of imprisonment in the agreement is “based on” a Guidelines sentencing range. In 2013, Defendant imposed the stipulated sentence of fifty-seven to seventy-one months’ imprisonment. In 2014, the United States Sentencing Commission retroactively reduced the base offense level for several drug offenses. Because many of his convictions were for controlled substance offenses, Defendant filed a motion to modify his sentence. The district court denied the motion. The First Circuit affirmed, holding that Defendant was not eligible for a sentencing reduction because his sentence was not “based on” a Guidelines sentencing range.
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