United States v. Marroquin-Medina, No. 15-12322 (11th Cir. 2016)
Annotate this CaseDefendant's original 72-month sentence represented a downward departure from his advisory guidelines range of 87 to 108 months based on his substantial assistance to the government. The district court applied a 3-level reduction in defendant’s offense level in making this downward departure. On appeal, defendant challenged the district court's order ruling on his motion for a sentence reduction under 18 U.S.C. 3582(c)(2) and Amendment 782 to the Sentencing Guidelines. The court concluded that USSG 1B1.10(b)(2)(B) grants the sentencing court in a section 3582(c)(2) proceeding the discretion to comparably reduce a defendant’s sentence where that defendant previously received a USSG 5K1.1 departure at his original sentencing. If a sentencing court chooses to exercise its discretion and make a comparable reduction, it is not bound to use the percentage-based approach - or any one specific method - to calculate the comparable reduction. Rather, the court may use any of the reasonable methods that were available to calculate the original section 5K1.1 departure, so long as they result in a comparable reduction. In this case, the district court’s mistaken belief about the limitation of its discretion constitutes procedural error. Accordingly, the court vacated and remanded.
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