United States v. Brown, No. 09-7561 (4th Cir. 2011)
Annotate this CaseDefendant pled guilty to maintaining a place at his residence for the purpose of manufacturing, distributing, and using cocaine base. The United States subsequently appealed the district court's grant of defendant's motion for a reduced sentence pursuant to 18 U.S.C. 3582(c)(2), arguing that the district court lacked the authority to grant such relief because defendant's sentence was not "based on" a sentencing range that was subsequently lowered but, rather, on his plea agreement entered pursuant to Federal Rule of Civil Procedure 11(c)(1)(C). The court held that, in light of the Supreme Court's recent opinion in Freeman v. United States, defendant's agreement did not satisfy the limited exception recognized in Justice Sotomayor's concurrence. Consequently, the plea agreement was the foundation for the term of imprisonment imposed and the district court lacked the authority under section 3582(c)(2) to grant defendant's motion for a reduced sentenced. Accordingly, the court reversed the district court's order granting defendant's motion.
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