United States v. Jehan, No. 19-1975 (7th Cir. 2020)
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Jehan led a Chicago street gang's conspiracy to distribute drugs. After he and others were indicted, Jehan fled and remained a fugitive for four years. After Jehan was arrested, the parties entered a plea agreement: Jehan admitted responsibility for conspiring to distribute more than 150 kilograms of cocaine, more than 30 kilograms of heroin, and more than 1.5 kilograms of crack, matching the thresholds for the highest base offense level on the drug‐quantity table, yielding a guidelines range of life in prison. In exchange for his acceptance of responsibility and aid to the government in other cases, the agreement specified that Jehan would receive a 300‐month sentence. In 2015, the court reduced Jehan’s sentence to 240 months because of his assistance in another case. In 2016, Jehan moved to reduce his sentence under 18 U.S.C. 3582(c)(2), citing Guidelines Amendment 782, which retroactively increased the drug quantities required for each base offense level for most federal drug offenses. The court denied Jehan’s motion because his sentence was “based on” the parties’ Rule 11(c)(1)(C) agreement, not the Guidelines. The Seventh Circuit affirmed. After the Supreme Court held, in 2018, that section 3582(c)(2) relief should be available to defendants with plea agreements, Jehan filed a second, unsuccessful motion.
The Seventh Circuit affirmed, stating that the district court held Jehan responsible for the quantities of narcotics necessary for the highest base offense level on the current drug‐quantity table. In deciding Jehan’s second 3582(c)(2) motion, the court determined that the same base offense level applied and let Jehan’s sentence stand; the court did not “retroactively increase” Jehan’s punishment, but only held that he was not entitled to the benefit of new policy changes.
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