United States v. Darden, No. 17-2435 (8th Cir. 2018)Annotate this Case
The Eighth Circuit affirmed the district court's denial of defendant's motion to reduce his sentence under Amendment 782. In this case, the district court determined that defendant was eligible for a reduced sentence under Amendment 782 and accurately calculated his amended Guidelines range. The court held that the district court did not make a clear or obvious error in considering post-sentencing conduct where defendant's attack on another individual lead to her death the following year. Furthermore, the district court did not make any conflicting findings; the district court could not be accused of performing a "plenary resentencing proceeding" when it decided to leave defendant's original sentence undisturbed; and the district court did not abuse its discretion by inadequately weighing defendant's post-sentencing rehabilitation efforts.