United States v. Koons, No. 15-3794 (8th Cir. 2017)
Annotate this CaseIn five consolidated appeals, defendants challenged the denial of their motions for sentence reductions under 18 U.S.C. 3582(c)(2) for convictions of methamphetamine conspiracy offenses. At issue was whether section 3582(c)(2) relief was now available because Amendment 782 to the Guidelines retroactively reduced by two levels the base offense levels assigned to drug quantities, lowering the advisory guidelines range for most drug offenses. The court concluded that these defendants were not eligible for a section 3582(c)(2) reduction because their sentences were not "based on" a guidelines range subsequently lowered by the Sentencing Commission. Accordingly, the court affirmed the judgment.
Court Description: Loken, Author, with Wollman and Benton, Circuit Judges] Criminal case - Sentencing. The five defendants in these consolidated appeals were not eligible for a Section 3582(c)(2) reduction because their sentences were not "based on" a guidelines range subsequently lowered by Amendment 782.
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