United States v. Taylor, No. 15-5930 (6th Cir. 2016)
Annotate this CaseTaylor was sentenced to 72 months’ imprisonment after pleading guilty to conspiracy to manufacture 5 grams or more of methamphetamine and aiding in maintaining a place for the purpose of manufacturing methamphetamine. Her guideline range was 108-135 months. The government moved for a downward departure, based on substantial assistance, to a sentence of 87 months, Taylor separately moved for a downward variance to 48 months. The court granted both motions in imposing the 72-month sentence. Amendments 782 and 788 to the Sentencing Guidelines, effective in 2014, retroactively lowered the guidelines for drug offenses by two levels. Taylor moved for a sentence reduction. Taylor’s amended guideline range was 87-108 months. Because Taylor’s original sentence was 33 percent below the guidelines range, she sought a sentence of 58 months, 33 percent below the amended range. The court stated that 19 percent of the original reduction was attributable to substantial assistance and reduced her sentence to 70 months, reasoning that U.S.S.G. 1B1.10(b)(2)(B) is limited to departures awarded pursuant to substantial assistance motions; variances and noncooperation departures are not awarded “pursuant to” such motions, so courts lack authority under section 3582(c)(2) to grant the relief requested. The Sixth Circuit affirmed, based on the history of section 1B1.10(b)(2) and the approaches of other circuits.
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