Vacated and remanded by published opinion. Chief Judge WILKINS wrote the majority opinion, in which Judge WILKINSON joins. Judge LUTTIG wrote a dissenting opinion.
OPINION
WILLIAM W. WILKINS, Chief Judge:
Anthony Goines appeals the denial of his motion to reduce his sentence pursuant to 18 U.S.C.A. § 3582(c)(2) (West 2000). We vacate and remand for further proceedings.
I.
In January 2000, Goines pled guilty to carrying a firearm during and in relation to a drag trafficking crime, see 18 U.S.C.A. § 924(c) (West 2000), and being an unlawful drag user in possession of a firearm, see 18 U.S.C.A. § 922(g)(3) (West 2000). These convictions arose from Goines’ possession of a firearm while he was selling and using illegal drags.
The district court sentenced Goines to . 60 months imprisonment for the § 924(c) offense and a consecutive term of 24 months for the § 922(g) offense. These terms were the product of separate analy-ses under the sentencing guidelines because § 924(c) requires a consecutive sentence. See 18 U.S.C.A. § 924(c)(l)(D)(ii); U.S. Sentencing Guidelines Manual § 5G1.2(a) (1998).1 With respect to the § 922(g) conviction, the district court, following the cross-references in U.S.S.G. § 2K2.1(c)(l)(A) and U.S.S.G. § 2Xl.l(a), applied the guideline for drag trafficking, U.S.S.G. § 2D1.1. The court ultimately arrived at an adjusted offense level of 17, which included a two-level enhancement based on Goines’ possession of a firearm during his drug transactions. See U.S.S.G. § 2D1.1(b)(1). This offense level, combined with Goines’ criminal history category of I, yielded a sentencing range of 24 to 30 months. The court sentenced Goines at the bottom of this range. Goines did not appeal.
After the district court entered its judgment, the Sentencing Commission adopted Amendment 599. This amendment modifies Application Note 2 (“Note 2”) to U.S.S.G. § 2K2.4, which governs sentencing for § 924(c) offenses. As is relevant here, Amendment 599 modified Note 2 to include the following language:
If a sentence under this guideline is imposed in conjunction with a sentence for an underlying offense, do not apply any specific offense characteristic for possession, brandishing, use, or discharge of an explosive or firearm when determining the sentence for the underlying offense. A sentence under this guideline accounts for any explosive or weapon enhancement for the underlying offense of conviction, including any such enhancement that would apply based on conduct for which the defendant is accountable under § IB 1.3 (Relevant Conduct) ....
If the explosive or weapon that was possessed ... in the course of the underlying offense also results in a conviction that would subject the defendant to an enhancement under ... § 2K2.1(b)(5) [472]*472(pertaining to possession of any firearm or ammunition in connection with another felony offense), do not apply that enhancement. A sentence under this guideline accounts for the conduct covered by th[at] enhancement ] because of the relatedness of that conduct to the conduct that forms the basis for the conviction under ... § 924(c).... For example, if in addition to a conviction for an underlying offense of armed bank robbery, the defendant was convicted of being a felon in possession under 18 U.S.C. § 922(g), the enhancement under § 2K2.1(b)(5) would not apply.
U.S.S.G.App. C, amend. 599 (internal quotation marks omitted).2 In restricting the application of certain enhancements, the Commission sought “to avoid the duplica-tive punishment that results when sentences are increased under both the statutes and the guidelines for substantially the same harm.” Id. (Reason for Amendment).
Relying on Amendment 599, Goines filed a § 3582(c)(2) motion asserting that his sentence should be recalculated without the § 2Dl.l(b)(l) enhancement. In response, the Government conceded that Goines was legally eligible for a sentence reduction but urged that his motion be denied based on other considerations that are relevant under § 3582(c)(2). The district court, however, refused to accept the Government’s concession and ruled that there was no legal basis for reducing Goines’ sentence. The court reasoned that the restrictions enacted by Amendment 599 do not apply to Goines because the offense for which he received a weapons enhancement — a violation of § 922(g)— was not the offense underlying his § 924(c) conviction.
II.
We initially consider whether Goines’ § 2D1.1(b)(1) enhancement was proper under Amendment 599. Although the district court held that it was, both Goines and the Government maintain that this was error. We agree with the parties.
As is relevant here, federal law provides three ways to penalize a defendant who unlawfully possessed a firearm and used or carried it during a drug trafficking offense. First, the defendant may be convicted and sentenced under § 924(c). Second, if the defendant is convicted of a drug trafficking offense (or sentenced under the drug trafficking guideline as the result of a cross-reference), U.S.S.G. § 2Dl.l(b)(l) provides for a two-level enhancement “[i]f a dangerous weapon (including a firearm) was possessed.” And third, if the defendant is convicted of unlawful possession of a firearm, his sentence may be enhanced for using the firearm “in connection with another felony offense.” U.S.S.G. § 2K2.1(b)(5).
Note 2 addresses the circumstances in which more than one of these penalties may apply. Even before it was modified by Amendment 599, Note 2 provided that a defendant who had been convicted of a drug trafficking offense and a § 924(c) violation could not receive a § 2Dl.l(b)(l) enhancement in addition to a sentence for the § 924(c) conviction. See U.S.S.G. § 2K2.4, comment, (n.2) (“Where a sentence under this section is imposed in conjunction with a sentence for an underlying offense, any specific offense characteristic for the possession, use, or discharge of an explosive or firearm ... is not to be applied in respect to the guideline for the underlying offense.”). Amendment 599 makes clear that it is also improper to [473]*473impose a § 2K2.1(b)(5) enhancement on a defendant who has been convicted of a firearms offense along with a § 924(c) violation. See U.S.S.G.App. C, amend. 599.
Goines’ case falls within a gap between these restrictions. He was convicted of a firearms possession offense, not the drug trafficking offense “underlying” his § 924(c) conviction, but his sentence for that conviction was computed pursuant to the drug trafficking guideline (§ 2D1.1), rather than the firearms possession guideline (§ 2K2.1). Nevertheless, Amendment 599 applies.
It appears that the Commission adopted the relevant portion of Amendment 599 in response to the decision of the Eleventh Circuit in United States v. Flennory, 145 F.3d 1264 (11th Cir.1998). In Flennory, as in this case, the defendant pled guilty to violations of § 922(g) and § 924(c), and the district court computed the § 922(g) sentence by cross-referencing § 2D1.1. See id. at 1266-67. The Eleventh Circuit upheld this sentence, rejecting the defendant’s claim that his sentence was unlawful under Note 2. See id. at 1269.
The commentary to Amendment 599 contrasts Flennory .with United States v. Smith, 196 F.3d 676 (6th Cir.1999), which expressly rejected Flennory in order to avoid imposing multiple enhancements based on the same conduct. See U.S.S.G.App. C, amend. 599 (Reason for Amendment) (citing Smith, 196 F.3d at 679-82). The paragraph of commentary following these citations explains that the purpose of the amendment is to avoid du-plicative punishments. See id. The best inference from this juxtaposition of citations and commentary is that, in adopting Amendment 599, the Sentencing Commission intended to repudiate Flennory and provide that a sentence for a § 922(g) offense may not be enhanced based on conduct that also resulted in a § 924(c) conviction. Indeed, the Eleventh Circuit has held that Amendment 599 overrules its decision in Flennory. See United States v. Brown, 332 F.3d 1341, 1345-46, 1345 n. 6 (11th Cir.2003). We agree and conclude that if Goines had been sentenced after Amendment 599 was adopted, he would not have been subject to a § 2Dl.l(b)(l) enhancement.
III.
Although Goines’ § 2D1.1(b)(1) enhancement was not proper under Amendment 599, this does not necessarily mean that he is eligible for relief under § 3582(c)(2). Section 3582(c)(2) authorizes the district court to reduce the sentence imposed on “a defendant who has been sentenced to a term of imprisonment based on a sentencing range that has subsequently been lowered by the Sentencing Commission pursuant to 28 U.S.C. § 994(o), ... if such a reduction is consistent with applicable policy statements issued by the Sentencing Commission.”
The applicable policy statement, U.S.S.G. § 1B1.10, expressly provides that Amendment 599 may be applied retroactively in a § 3582(c)(2) proceeding. See U.S.S.GApp. C, amend. 607 (adding Amendment 599 to the list of retroactive guideline amendments in § lB1.10(c)). Our precedent suggests that nothing more is required in order for Amendment 599 to be a proper basis for a § 3582(c)(2) motion. See United States v. Fletcher, 74 F.3d 49, 56 (4th Cir.1996) (stating that, because the amendment relied on by the movant was listed in § 1B1.10, “a sentence reduction is authorized ... pursuant to 18 U.S.C. § 3582(c)(2)”). Fletcher, however, did not address the question before us — namely, whether an amendment that merely clarifies the meaning of the relevant guideline “lower[s]” the “sentencing range” for purposes of § 3582(c)(2).
[474]*474As we will explain below, the answer to this question depends on whether the term “sentencing range” refers to the range intended by the Sentencing Commission or the range actually applied by the district court in a particular case. We hold that the “sentencing range” is the range actually applied by the district court.
A.
We begin our analysis with a brief discussion of guidelines amendments, which will help frame our inquiry into the meaning of § 3582(c)(2). By statute, the Sentencing Commission must “periodically ... review and revise” the guidelines. 28 U.S.C.A. § 994(o) (West 1993). In carrying out this function, the Commission may promulgate both clarifying and substantive amendments. See generally United States v. Butner, 277 F.3d 481, 489 (4th Cir.) (explaining how to distinguish clarifying amendments from substantive amendments), cert. denied, 536 U.S. 932, 122 S.Ct. 2610, 153 L.Ed.2d 795 (2002).
A clarifying amendment “changes nothing concerning the legal effect of the guidelines, but merely clarifies what the Commission deems the guidelines to have already meant.” United States v. Capers, 61 F.3d 1100, 1109 (4th Cir.1995) (internal quotation marks omitted). The Commission often uses clarifying amendments to resolve disagreements among courts of appeals. See United States v. Innie, 77 F.3d 1207, 1209 (9th Cir.1996). A clarifying amendment must be given effect at sentencing and on appeal, even when the sentencing court uses an edition of the guidelines manual that predated adoption of the amendment. See U.S.S.G. § 1B1.11(b)(2), p.s.; Capers, 61 F.3d at 1109.
Unlike a clarifying amendment, a substantive amendment “has the effect of changing the law in this circuit.” Capers, 61 F.3d at 1110. Substantive amendments typically reflect new policy choices by the Commission. See, e.g., U.S.S.G.App. C., amend. 634 (Reason for Amendment) (explaining that Commission amended money laundering guidelines because old guidelines did not sufficiently account for seriousness of offense or defendant’s degree of involvement). A defendant is not entitled to the benefit of a substantive amendment that was adopted after the guidelines manual used at the defendant’s sentencing unless the Sentencing Commission has designated the amendment for retroactive application. See U.S.S.G. § IB 1.10(a), p.s.
Even if an amendment is designed merely to elucidate the original intent of the Commission, we will regard it as substantive if it conflicts with our precedent. See Capers, 61 F.3d at 1110. Thus, some amendments that would otherwise be considered clarifying will be treated as substantive amendments in this circuit. We will refer to such amendments as “hybrid amendments.”
The amendment at issue here, Amendment 599, does not conflict with any decision of this court. For this reason, and in light of the factors set forth in Butner, we conclude that Amendment 599 is a clarifying amendment. Accord United States v. Aquino, 242 F.3d 859, 865 (9th Cir.2001).
B.
We now turn to the task of interpreting § 3582(c)(2). In construing this statute, we “must account for [its] full text, language as well as punctuation, structure, and subject matter.” United States Nat’l Bank of Or. v. Indep. Ins. Agents of Am., Inc., 508 U.S. 439, 455, 113 S.Ct. 2173, 124 L.Ed.2d 402 (1993); see id. (“Over and over we have stressed that in expounding on a statute, we must not be guided by a single sentence or member of a sentence, but look to the provisions of the whole law, [475]*475and to its object and policy.” (internal quotation marks omitted)).
Considering the language alone, we perceive two possible readings of the relevant language of § 3582(c)(2). A narrow reading would authorize a sentence reduction when the “sentencing range [;prescribed by the sentencing guidelines ] has subsequently been lowered” by a retroactive amendment. By contrast, a broad reading would allow a defendant’s sentence to be reduced if the “sentencing range [applied by the district court ] has subsequently been lowered” by a retroactive amendment. The narrow reading would bar § 3582(c)(2) motions relying on clarifying and hybrid amendments, as those amendments do not change the meaning of the guideline and thus do not alter the range intended by the guidelines, although the sentencing court may have applied a different range. The broad reading, by contrast, would allow a defendant to file a § 3582(c)(2) motion based on any amendment given retroactive application by the Commission, so long as his sentencing range under the amended guideline would be lower than the range applied by the district court.
Both of these readings are plausible.3 However, after examining the role of guideline amendments, the general remedial structure associated with the sentencing guidelines, and the consequences of adopting a broad rather than a narrow construction of § 3582(c)(2), we conclude that the broad reading better effectuates the congressional intent underlying § 3582(c)(2).
1.
The Sentencing Reform Act of 1984, Pub.L. No. 98-473, ch. II, 98 Stat. 1987-2040 (1984), created the Sentencing Commission and gave it the power to promulgate and amend sentencing guidelines. See generally 28 U.S.C.A. § 994 (West 1993 & Supp.2003). In conferring this power, “Congress necessarily contemplated that the Commission would periodically review the work of the courts, and would make whatever clarifying revisions to the Guidelines conflicting judicial decisions might suggest.” Braxton v. United States, 500 U.S. 344, 348, 111 S.Ct. 1854, 114 L.Ed.2d 385 (1991). In other words, Congress anticipated that the Commission would use the amendment process to resolve disagreements among courts of appeals. See Douglas A. Berman, The Sentencing Commission as Guidelines Supreme Court: Responding to Circuit Conflicts, 7 Fed. Sentencing Rep. 142, 142 (1994).
This activity by the Commission is essential to the proper functioning of the guidelines. One of the main goals of the [476]*476Sentencing Reform Act was “the elimination of unwarranted sentencing disparity.” S.Rep. No. 98-225, at 52 (1983), reprinted in 1984 U.S.C.C.A.N. 3182, 3235. Divergent interpretations of the guidelines, however, can result in wildly disparate sentences. See William W. Wilkins, Jr. & John R. Steer, The Role of Sentencing Guideline Amendments in Reducing Unwarranted Sentencing Disparity, 50 Wash. & Lee L.Rev. 63, 71-72 (1993). Moreover, the Supreme Court has noted that Congress apparently intended for the Sentencing Commission to have substantial responsibility for resolving disputes among the circuits. See Braxton, 500 U.S. at 348, 111 S.Ct. 1854. Consequently, the amendment process is a significant tool for resolving circuit conflicts in order to ensure uniform application of the guidelines.
Clarifying and hybrid amendments are thus necessary to address disagreements among the courts of appeals. While it does not necessarily follow that such amendments should be applied to defendants whose judgments have become final, “Congress has granted the Commission the unusual explicit power to decide whether and to what extent its amendments reducing sentences will be given retroactive effect.” Id. (emphasis omitted). The amendment and retroactivity powers operate in tandem: The Commission decides how to modify the guidelines and also decides how such modifications should be implemented. This is appropriate, as the Commission has both the authority and the obligation to enact policies designed to achieve the underlying purposes of the Sentencing Reform Act. See, e.g., 28 U.S.C.A. § 994(c) (listing factors for Commission to consider in formulating guidelines).
An interpretation of § 3582(c)(2) that precluded sentence reductions based on clarifying or hybrid amendments would curtail the ability of the Commission to eliminate sentencing disparities through the amendment process. Although the Commission would retain the power to prevent future misapplications of the guidelines, it would lose the authority to correct past errors, thereby undermining its ability to amend the guidelines in the manner and sequence best calculated to promote the goals of the Sentencing Reform Act. This would likely lead to the Supreme Court having to assume a greater role in resolving circuit conflicts in order to correct errors that could not be remedied by the Commission. Because this redistribution of the burden of rectifying erroneous applications of the guidelines would conflict with the congressional allocation of authority, an interpretation of § 3582(c)(2) leading to such a redistribution — i.e., a narrow interpretation barring motions based on clarifying or hybrid amendments — should be avoided.
2.
In addition to shifting responsibility for resolving circuit conflicts, a narrow reading of § 3582(c)(2) would undermine the remedial scheme created by the Sentencing Reform Act. Under this scheme, a defendant whose sentence was computed improperly under the guidelines has, at most, three remedies. First, he can challenge the sentence on direct appeal. See 18 U.S.C.A. § 3742(a) (West 2000). Second, he can file an application for post-conviction relief pursuant to 28 U.S.C.A. § 2255 (West Supp.2003). See 18 U.S.C.A. § 3582(c)(1)(B) (West Supp.2003) (authorizing district courts to modify sentences “to the extent ... expressly permitted by statute”). And third, if the Commission adopts a retroactive amendment demonstrating that the guidelines were applied incorrectly, the defendant can file a § 3582(c)(2) motion.
While we certainly encourage the full exercise of appeal rights, we also recognize [477]*477that the prospects for appellate relief are uncertain at best when the applicable guideline is ambiguous. Such ambiguities may result in disagreements among courts of appeals, with some courts endorsing more severe sentences than the Commission intended. The Supreme Court is not likely to correct those sentences; as noted above, the Commission bears substantial responsibility for resolving circuit conflicts. Thus, direct review may not provide an adequate remedy for a defendant sentenced incorrectly based on an ambiguous guideline.
For its part, § 2255 provides virtually no remedy at all. The Sentencing Reform Act does not bar § 2255 relief based on incorrect application of the guidelines, but Supreme Court decisions predating the Act state that, in the absence of “a complete miscarriage of justice,” § 2255 review is limited to constitutional and jurisdictional challenges. E.g., Stone v. Powell, 428 U.S. 465, 477 n. 10, 96 S.Ct. 3037, 49 L.Ed.2d 1067 (1976) (internal quotation marks omitted). Thus, guideline claims ordinarily are not cognizable in § 2255 proceedings. See United States v. Mikalajunas, 186 F.3d 490, 496 (4th Cir.1999); accord Jones v. United States, 178 F.3d 790, 796 (6th Cir.1999); Burke v. United States, 152 F.3d 1329, 1331-32 (11th Cir.1998).
This leaves § 3582(c)(2). A narrow interpretation of § 3582(c)(2), however, would bar relief based on amendments that merely elucidate — rather than change — the meaning of the relevant guidelines. This would effectively eliminate all opportunities for correction of a sentence that was consistent with circuit precedent at the time of sentencing but inconsistent with the intent of the Commission, as expressed in a subsequent hybrid amendment.
We could hold that a miscarriage of justice occurs — and thus § 2255 relief is available — in cases in which the defendant’s sentence was consistent with circuit precedent but would be erroneous under a hybrid amendment adopted after the defendant’s judgment became final. Such a rule would enable us to adopt a narrow interpretation of § 3582(c)(2) without entirely foreclosing guidelines-based collateral challenges. This approach, however, would shift collateral litigation from a procedure specifically created for guidelines claims to a procedure generally reserved for correction of constitutional and jurisdictional errors.
We do not believe that Congress intended this result. Nor do we believe that Congress — having “necessarily contemplated” conflicting interpretations of the guidelines, Braxton, 500 U.S. at 348, 111 S.Ct. 1854, and having posited a relatively circumscribed role for the Supreme Court in resolving such conflicts- — intended for direct review to serve as the sole remedy for guideline errors. We therefore conclude that a broad interpretation of § 3582(c)(2) best implements the remedial scheme established by the Sentencing Reform Act.
3.
Although it appears from the analysis above that a broad reading of § 3582(c)(2) reflects the intent of Congress better than a narrow reading, we must also consider whether a broad reading would have effects that Congress sought to avoid. We conclude that it would not.
Whether construed broadly or narrowly, § 3582(c)(2) impairs the finality of criminal judgments. We acknowledge that this concern is greater under the broad reading, because that reading affords more leeway for post-judgment motions. Nevertheless, under either reading of the statute, such motions are permitted only in cases that have been selected by the Sen[478]*478tencing Commission. As noted above, Congress endowed the Commission with broad powers to authorize retroactive application of guideline amendments. In so doing, Congress delegated to the Commission the authority to decide when a final judgment may be revised. Thus, the disruption of finality engendered by a broad interpretation of § 3582(c)(2) is consistent with the legislative design.
Another potential problem resulting from the broad interpretation is that it may confer a windfall on defendants who could have obtained relief on appeal. As we have discussed, however, the prospects for appellate relief are uncertain at best when a guideline or its commentary is ambiguous. Furthermore, a broad interpretation of § 3582(c)(2) does not diminish defendants’ incentive to raise possibly meritorious sentencing claims on appeal, as § 3582(c)(2), unlike direct review, requires the intervention of the Sentencing Commission and, additionally, is subject to the discretion of the district court. Accordingly, a broad construction of § 3582(c)(2) does not interfere with any general policy favoring correction of errors on direct review.
C.
The dissent contends that our analysis of § 3582(c)(2) is incorrect in light of U.S.S.G. § lB1.10(a) and 28 U.S.C.A. § 994(u). We respectfully disagree.
Section lB1.10(a) states:
Where a defendant is serving a term of imprisonment, and the guideline range applicable to that defendant has subsequently been lowered as a result of an amendment to the Guidelines Manual listed in subsection (c) below, a reduction in the defendant’s term of imprisonment is authorized under 18 U.S.C. § 3582(c)(2). If none of the amendments listed in subsection (c) is applicable, a reduction in the defendant’s term of imprisonment under 18 U.S.C. § 3582(c)(2) is not consistent with this policy statement and thus is not authorized.
The accompanying commentary reiterates that “[ejligibility for consideration under 18 U.S.C. § 3582(c)(2) is triggered only by an amendment listed in subsection (c) that lowers the applicable guideline range.” U.S.S.G. § 1B1.10, comment, (n.l).
As construed by the dissent, § lB1.10(a) establishes two discrete prerequisites that an amendment must satisfy in order to support a § 3582(c)(2) motion: the amendment must be listed in § lB1.10(c), and it must lower the “applicable” guideline range. It is undisputed that Amendment 599 satisfies the first of these requirements. We believe that this is sufficient, and that § 1B1.10(a) does not in fact impose the second requirement postulated by the dissent.
We readily acknowledge that the word “applicable,” as used in § 1B1.10(a), seems to refer to the range prescribed by the guidelines rather than the range applied by the sentencing court. But we cannot square this interpretation with the inclusion of clarifying amendments in § lB1.10(c).4 Because the sole purpose of [479]*479that subsection is to identify amendments that may be applied retroactively in § 3582(c)(2) proceedings, we cannot imagine why the Commission would include within § 1B1.10(c) any amendment that did not meet the Commission’s own requirements for retroactive application. Cf. U.S.S.G.App. C., amend. 423 (modifying a proviso restricting § 3582(c)(2) motions and indicating that the Commission only lists amendments in § 1B1.10 if they satisfy all the requirements for eligibility for § 3582(c)(2) relief).
The dissent resolves this conundrum by treating the inclusion of clarifying amendments in § lB1.10(c) as an invalid reading of § lB1.10(a). But § 1B1.10(c) is not a subordinate enactment interpreting § lB1.10(a); on the contrary, it is part of the same provision as § 1B1.10(a), adopted by the same agency and entitled to the same weight, even if it represents a departure from views previously announced by the Commission, see Rust v. Sullivan, 500 U.S. 173, 186, 111 S.Ct. 1759, 114 L.Ed.2d 233 (1991). Thus, in order to implement § 1B1.10 in its entirety, we are forced to choose between stretching the meaning of the word “applicable” or rendering portions of § lB1.10(c) nugatory.
We choose the former course, for two reasons. First, as the dissent recounts, the relevant text of § lB1.10(a) predates the inclusion of clarifying amendments in § lB1.10(c); thus, § 1B1.10(c) represents the Commission’s current views on retro-activity of guidelines amendments, and we must give effect to this reading, so long as it is consistent with applicable statutes.5 Cf. Stinson v. United States, 508 U.S. 36, 46-47, 113 S.Ct. 1913, 123 L.Ed.2d 598 (1993) (rejecting the Commission’s statement regarding the role of guidelines commentary and instead relying on “the uses to which the Commission in practice has put such commentary”). Second, requiring § 3582(c)(2) petitioners to demonstrate that they are relying on substantive amendments would enhance the role of the courts in the § 3582(c)(2) process while limiting the discretion of the Sentencing Commission to give retroactive effect to its guideline revisions. Faced with a choice between limiting our own discretion and limiting that of the agency with primary responsibility for formulating and administering the guidelines, we prefer to limit our own discretion (at least until Congress, the Supreme Court, or the Commission instructs otherwise). Accordingly, we interpret § 1B1.10 to authorize § 3582(c)(2) motions based on any amendment listed in § lB1.10(c), without regard to whether that amendment is substantive or clarifying.
The final provision cited by the dissent to illuminate the meaning of § 3582(c)(2) is 28 U.S.C.A. § 994(u), which states:
If the Commission reduces the term of imprisonment recommended in the guidelines applicable to a particular offense or category of offenses, it shall specify in what circumstances and by what amount the sentences of prisoners serving terms of imprisonment for the offense may be reduced.
The dissent contends that this provision precludes the Commission from giving retroactive effect to clarifying amendments.
The plain language of § 994(u) — viewed without benefit of prior judicial interpreta[480]*480tions- — appears to authorize retroactive application of substantive amendments only. However, we may not construe this statute without considering the views expressed by the Supreme Court in Braxton v. United States, 500 U.S. 344, 111 S.Ct. 1854, 114 L.Ed.2d 385 (1991). In Braxton, the Supreme Court cited § 994(u) to support the proposition that “Congress has granted the Commission the unusual explicit power to decide whether and to what extent its amendments reducing sentences will be given retroactive effect.” Id. at 348, 111 S.Ct. 1854 (emphasis omitted). Significantly, the Court relied on this power in the course of declining to resolve a circuit conflict that the Commission had undertaken to resolve with a clarifying amendment. See id. at 347-48, 111 S.Ct. 1854; see also U.S.S.G.App. C., amend. 434 (resolving the issue left open in Braxton).
Although the Court ultimately granted relief to Braxton on other grounds, those grounds were “closely tied to the facts of the present case.” Braxton, 500 U.S. at 349, 111 S.Ct. 1854. In other words, the Supreme Court eschewed a broadly applicable legal decision in favor of a decision narrowly limited to the facts of a particular case, in contravention of the Court’s usual preference for avoiding narrow, fact-specific decisions, cf. Sup.Ct. R. 10 (stating that Supreme Court will only grant certiorari “for compelling reasons” and that such reasons ordinarily involve disputes among lower courts or “important question[s] of federal law”). Moreover, the primary reason for this choice was that the Sentencing Commission was fully empowered to address the broader legal issue and to rectify any harms that might have resulted from incorrect interpretations of the relevant guideline. Indeed, the Court speculated — consistently with our analysis of § 3582(c)(2)- — that this power may be so great as to give the Commission a role at least equal to that of the Supreme Court in resolving disputes concerning the interpretation of the sentencing guidelines. See Braxton, 500 U.S. at 348, 111 S.Ct. 1854 (stating that the Court ordinarily regards the task of resolving disputes among circuit courts as “initially and primarily ours” but that “this may not be Congress’ intent with respect to the Sentencing Guidelines”).
Under these circumstances, it would be inappropriate to treat the statements of the Supreme Court regarding § 994(u) as mere dictum. Instead, these statements reflect a determination that the Commission has the power to give retroactive effect to clarifying amendments. This determination is binding here. We therefore conclude that neither § 994(u) nor U.S.S.G. § lB1.10(a) precludes Goines from bringing this § 3582(c)(2) action based on Amendment 599.
IV.
For the foregoing reasons, we hold that a defendant may rely on a clarifying or hybrid amendment to support a § 3582(c)(2) motion, so long as the amendment has been designated for retroactive application and would result in application of a sentencing range lower than the range applied at the original sentencing proceeding. We further hold that Amendment 599 meets these criteria. Accordingly, we conclude that the district court erred in ruling that Goines was ineligible for § 3582(c)(2) relief as a matter of law.
The Government agrees with this conclusion but asserts that Goines nevertheless is not entitled to § 3582(c)(2) relief because no modification of his sentence is warranted under 18 U.S.C.A. § 3553(a) (West 2000). See 18 U.S.C.A. § 3852(c)(2) (providing that district court may reduce sentence based on retroactive change to guidelines “after considering the factors set forth in section 3553(a)”). That question, however, should be considered by the [481]*481district court in the first instance. Accordingly, we vacate the decision of the district court and remand for consideration of whether Goines’ sentence should be reduced.
VACATED AND REMANDED