United States v. Brown, No. 15-1437 (8th Cir. 2015)
Annotate this CaseBrown pleaded guilty to distributing cocaine base, 21 U.S.C. 841(a)(1),under a plea agreement, stating that the sentence to be imposed, “pursuant to [Federal Rule of Criminal Procedure] 11(c)(1)(C), shall be the greater of the minimum sentence under the U.S.S.G. range as determined by the District Court, or 100 months.” The court accepted the plea and sentenced Brown to 100 months in prison. In 2011, Brown moved for a sentence reduction under 18 U.S.C. 3582(c)(2), which authorizes a court to reduce “a term of imprisonment based on a sentencing range that has subsequently been lowered by the Sentencing Commission.” The government agreed that Brown was entitled to a reduction. The court reduced Brown’s sentence to 70 months. In 2014, Brown moved for a further reduction based on 2014 Guidelines amendments. The court found that Brown was not eligible for a reduction, because he had not been sentenced based on a Guidelines range, but based on a Rule 11(c)(1)(C) plea agreement. Brown argued that his plea agreement shows that a Guidelines range was used to establish his sentence, and that the government should be bound by its 2011 position. The Eighth Circuit reversed: where a plea agreement is ambiguous, the ambiguities are construed against the government.
Court Description: Per Curiam - Before Wollman, Loken and Benton, Circuit Judges] Criminal case - Sentencing. The district court erred in determining defendant was not eligible for a sentence reduction under 18 U.S.C. Sec. 3582(c)(2) as his sentence was based on a guidelines range and not on the Rule 11(c)(1)(C) plea agreement
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