United States v. Carosella, No. 17-896 (2d Cir. 2018)Annotate this Case
The Second Circuit affirmed the district court's denial of defendant's motion to reduce his sentence pursuant to 18 U.S.C. 3582(c) and Amendment 782 to the United States Sentencing Guidelines. The court held that the district court correctly determined that defendant was ineligible for a sentence reduction, where there was no change to the bottom-line, final range that was the basis for defendant's sentence because of the operation of another guideline -- the grouping rules provided in USSG 3D1.4. The court joined its sister circuits in holding that USSG 1B1.10(b)(1) unambiguously did not support defendant's interpretation, and thus the rule of lenity did not apply.