United States v. Bryant, No. 19-14267 (11th Cir. 2021)Annotate this Case
Defendant, a corrupt former police officer who was sentenced to prison for running drugs and guns, filed a motion seeking a reduction in his sentence under 18 U.S.C. 3582(c)(1)(A). The district court denied the motion based on the Sentencing Commission's policy statement found at USSG 1B1.13.
The Eleventh Circuit affirmed and concluded that section 1B1.13 is an applicable policy statement for all section 3582(c)(1)(A) motions, and Application Note 1(D) does not grant discretion to courts to develop "other reasons" that might justify a reduction in a defendant's sentence. In this case, because defendant's motion does not fall within any of the reasons that section 1B1.13 identifies as "extraordinary and compelling," the district court correctly denied his motion for a reduction of his sentence.