United States v. Jose Charriez

CourtCourt of Appeals for the Third Circuit
DecidedFebruary 19, 2026
Docket24-2964
StatusUnpublished

This text of United States v. Jose Charriez (United States v. Jose Charriez) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Jose Charriez, (3d Cir. 2026).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ____________

No. 24-2964 ____________

UNITED STATES OF AMERICA

v.

JOSE CHARRIEZ a/k/a Jun, Appellant ____________

On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. No. 2:16-cr-00025-001) District Judge: Michael M. Baylson ____________

Submitted Under Third Circuit LAR 34.1(a) February 6, 2026

Before: HARDIMAN, MONTGOMERY-REEVES, and ROTH, Circuit Judges.

(Filed: February 19, 2026)

____________

OPINION * ____________

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. HARDIMAN, Circuit Judge.

Jose Charriez, pro se, appeals the District Court’s order denying his motion for

reduction in sentence under 18 U.S.C. § 3582(c)(1)(A)(i). We will affirm.

I

Charriez pleaded guilty to three federal gun and drug charges. At sentencing in

2017, the District Court determined Charriez was a career offender under the United

States Sentencing Guidelines § 4B.1(a). The Court applied § 4B1.1(c)(3) and calculated

Charriez’s Guidelines range as 262 to 327 months’ imprisonment.

Defense counsel argued that Charriez’s Guidelines range would be substantially

lower but for his 2009 Delaware state conviction for delivery of a controlled substance

involving marijuana, which was one of two predicate offenses that triggered the career

offender enhancement. In response, the District Court described that Delaware marijuana

trafficking offense as a “less serious offense than distributing cocaine, or crack, or

heroin,” and stated, “to be fair to the Defendant, [the Court] [had] to take [that] into

account.” Dist. Ct. Dkt. No. 36, at 13–14, 18.

The District Court also explained that, if Charriez’s current offenses were not so

serious, it would have considered sentencing him “along the lines of” the non-career

offender Guidelines range requested by defense counsel. Dist. Ct. Dkt. No. 36, at 29. It

explicitly took the less serious nature of the 2009 Delaware marijuana offense into

account. Accordingly, it imposed concurrent sentences of 120 months’ imprisonment at

Counts One and Three and the mandatory minimum sentence of 60 months’

imprisonment at Count Two to be served consecutive to the other sentences, resulting in a

2 total sentence of 180 months’ imprisonment—a substantial downward variance from

Charriez’s Guidelines range.

In 2024, Charriez moved for a reduction in sentence. He contended that

extraordinary and compelling circumstances existed under Guidelines § 1B1.13(b)(6). In

support of his motion, Charriez argued that the “attitude . . . with respect to marijuana

laws has seen a drastic [c]hange” nationwide and in Delaware, such that “[c]hanges in the

[m]arijuana laws [would] affect his prior criminal history and reduce his criminal history

status.” Dist. Ct. Dkt. No. 54, at 8. Thus, his 2009 Delaware marijuana conviction would

no longer qualify as a predicate crime for the career offender enhancement, resulting in a

“gross disparity” between the sentence he received and the sentence that would be

imposed. Dist. Ct. Dkt. No. 54, at 8–9.

The District Court denied the motion. It found no gross disparity between the

sentence Charriez was serving—one for which the Court had considered the less serious

nature of the marijuana offense and varied downward from the Guidelines substantially—

and any sentence that would be imposed on the motion.

Charriez timely appealed.1

1 Charriez also appeals the District Court’s order granting an extension to the Government to respond to his motion, where the Government filed the request two days after the Court’s response deadline. Charriez Br. 3–4. The Chief of Appeals for the United States Attorney’s Office explained that the motion was never served, the assigned attorney was no longer employed by that office, and he was unaware of Charriez’s original filing and the Court’s ordered response. The District Court granted the extension over Charriez’s objection. Perceiving no abuse of discretion in the Court allowing the extension based on the Government’s explanation, we will affirm that order. See In re Fine Paper Antitrust Litig., 685 F.2d 810, 817 (3d Cir. 1982).

3 II 2

Under § 3582(c)(1)(A)(i), a district court may reduce a term of imprisonment “if it

finds that [] extraordinary and compelling reasons warrant such a reduction” after

considering the applicable sentencing factors set forth in 18 U.S.C. § 3553(a). The

threshold determination—whether extraordinary and compelling circumstances exist to

permit that exercise of discretion—is a question of law, which we review de novo. The

same is true for whether a conviction is a predicate offense under the Guidelines. See

United States v. Womack, 55 F.4th 219, 236 (3d Cir. 2022). But the ultimate decision to

grant a motion for reduction in sentence is discretionary and reviewed accordingly.

United States v. Pawlowski, 967 F.3d 327, 330 (3d Cir. 2020).

Charriez argues that the District Court erred in denying his motion for reduction

because it “conceded” that he “would no longer be deemed a ‘Career Offender’” yet

found “there is not a gross disparity between the sentence he is serving and the sentence

that would likely be imposed.” Charriez Br. 4. He reasserted that if he were sentenced

today, “he would no longer be deemed a Career Offender” and “would [be] released from

incarceration.” Charriez Br. 6. 3

We perceive no abuse of discretion in the District Court’s denial of the motion and

2 The District Court had jurisdiction under 18 U.S.C. § 3231. We have jurisdiction under 28 U.S.C. § 1291. 3 Before the District Court and in his reply here, Charriez argued other bases in support of extraordinary and compelling circumstances that he did not address in his opening brief, so they are forfeited. M.S. ex rel. Hall v. Susquehanna Twp. Sch. Dist., 969 F.3d 120, 124 n.2 (3d Cir. 2020). 4 its determination that there would be no gross disparity in sentences. Contrary to

Charriez’s assertion, the District Court’s statement in its order denying the motion merely

acknowledged Charriez’s argument that he might not be considered a career offender

today; the Court did not rule on that issue in his favor. Irrespective of that classification,

the District Court recognized at sentencing the more lenient treatment of marijuana

offenses. And when it gave Charriez the substantial downward variance, the Court

considered the non-career offender Guidelines range and justified the sentence imposed

by stating that the marijuana trafficking offense was less severe than trafficking cocaine,

crack, or heroin. The very same arguments that Charriez raises now about the severity of

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United States v. Jose Charriez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-jose-charriez-ca3-2026.