United States v. Hernandez-Martinez, No. 15-30309 (9th Cir. 2019)
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Defendants brought these consolidated appeals seeking to reduce their sentences under 18 U.S.C. 3582(c)(2), which allows a court to reduce in certain circumstances a previously imposed sentence, for drug-related offenses.
The Ninth Circuit held that the Supreme Court's decision in Hughes v. United States, 138 S. Ct. 1765 (2018), and this circuit's decision in United States v. Padilla-Diaz, 862 F.3d 856 (9th Cir. 2017), were fully compatible and that Padilla-Diaz, which upheld USSG 1B1.10(b)(2), remains binding precedent. The panel explained that the question considered in Hughes was entirely different from those addressed in Padilla-Diaz. Hughes did not consider at all the import of section 1B1.10(b)(2)(A), the provision limiting sentence reductions to the lowest term recommended by the revised Guidelines range. Furthermore, Hughes did not conclude that general sentencing policies constrain section 3582(c)(2) proceedings, and nothing in Hughes addressed inter-defendant sentencing uniformity more generally, much less the sentence reduction limitation at issue here. Therefore, the panel was bound by Padilla-Diaz's conclusion regarding the interplay between the Guidelines policy statement contained in section 1B1.10(b)(2) and section 3582(c)(2). Accordingly, the panel affirmed the district court's denial of defendants' motions.
Court Description: Criminal Law. The panel affirmed the district court’s denials of twenty- three defendants’ motions pursuant to 18 U.S.C. § 3582(c)(2) for sentence reductions based on retroactive Sentencing Guidelines Amendment 782, which revised the Guidelines’ drug quantity table by reducing the base offense level for most drugs and quantities by two levels. The district courts denied the motions, concluding that the defendants were categorically ineligible in light of U.S.S.G. § 1B1.10(b)(2)(A), which generally prohibits a sentence reduction if the original term of imprisonment is below the lower end of the amended Guidelines range. The district courts further concluded that the defendants were not eligible for relief under the limited exception set forth in U.S.S.G. § 1B1.10(b)(2)(B), which applies when a defendant’s original term of imprisonment was below the Guidelines range because of a reduction for substantial assistance to authorities and a § 3582(c)(2) sentence * The Honorable Eduardo C. Robreno, United States District Judge for the Eastern District of Pennsylvania, sitting by designation. 10 UNITED STATES V. HERNANDEZ-MARTINEZ reduction would be comparably below the amended Guidelines range. The panel rejected the defendants’ argument that United States v. Padilla-Diaz, 862 F.3d 856 (9th Cir. 2017)—which upheld § 1B1.10(b)(2), including its limited exception for substantial assistance departures, as consistent with both the governing statutes and constitutional requirements—is irreconcilable with the Supreme Court’s later decision in Hughes v. United States, 138 S. Ct. 1765 (2018). The panel explained that Hughes considered an entirely different issue, when it held that a sentence imposed pursuant to a Fed. R. Crim. P. 11(c)(1)(C) plea agreement is “based on” the defendant’s Guidelines so long as that range was part of the framework the district court relied on in imposing the sentence or accepting the agreement. Because the intervening decision in Hughes is not in conflict with Padilla-Diaz, the panel concluded that it was bound by Padilla-Diaz’s conclusion regarding the interplay between the Guidelines policy statement contained in § 1B1.10(b)(2) and § 3582(c)(2).
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