United States v. Heaton, No. 17-3314 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit reversed the district court's order reducing defendant's term of imprisonment in light of Amendment 782 of the Sentencing Guidelines. The court held that the district court impermissibly reduced defendant's sentence below his amended guideline range. The court held that any reduction below 110 months was inconsistent with the policy statement in USSG 1B1.10(b)(2)(A) and thus unauthorized by 18 U.S.C. 3582(c)(2). In this case, it was not irrational for the Commission to avoid undue complexity and litigation by adopting a uniform limitation on reductions tied to the amended guidelines range. Accordingly, the court remanded for a resentencing consistent with the limitation that the sentence must not be less than the 110-month minimum of the amended guideline range.
Court Description: Colloton, Author, with Wollman and Benton, Circuit Judges] Criminal case - Sentencing. In granting a sentencing reduction under Amendment 782, the district court erred under the policy statement in Guidelines Sec. 1B1.10(b)(2)(A) in reducing defendant's sentence below the minimum amended guideline range; constitutional challenge to Sec. 1B1.10 rejected as it was not irrational for the Commission to avoid undue complexity and litigation by adopting a uniform limitation on reductions tied to the amended guidelines range; reversed and remanded for entry of sentence not less than the applicable 110-month minimum of the amended guidelines range.
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