United States v. Hernandez-Martinez, No. 15-30309 (9th Cir. 2019)Annotate this Case
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.