United States v. Lance Williams

808 F.3d 253, 2015 WL 8603010
CourtCourt of Appeals for the Fourth Circuit
DecidedDecember 14, 2015
Docket15-7114
StatusPublished
Cited by63 cases

This text of 808 F.3d 253 (United States v. Lance Williams) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth 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. Lance Williams, 808 F.3d 253, 2015 WL 8603010 (4th Cir. 2015).

Opinions

Vacated and remanded by published opinion. Judge KING wrote the majority opinion, in which Judge THACKER joined. Chief Judge TRAXLER wrote a dissenting opinion.

KING, Circuit Judge:

Lance Antonio Williams appeals from the district court’s denial of his motion for a reduced sentence under 18 U.S.C. § 3582(c)(2). Williams seeks the benefit of recent amendments to the Sentencing Guidelines and contends that the court in the Middle District of North Carolina erred when it ruled him ineligible for a sentence reduction. According to Williams, Guidelines Amendment 780, which revised the policy statement governing § 3582(c)(2) sentence reductions, renders him eligible for relief. The United States Attorney supports Williams’s position in this appeal. As explained below, we vacate and remand.1

■ I.

On March 3, 2008, Williams pleaded guilty to distributing cocaine base, in contravention of 21 U.S.C. § 841(a)(1). Prior to his guilty plea, the United States Attorney filed a notice, pursuant to 21 U.S.C. § 851, advising Williams and the district court that Williams’s prior North Carolina drug conviction would be utilized to seek an enhanced penalty under § 841(b)(1)(A).2

The Probation .Officer prepared. Williams’s presentence report (the “PSR”) and recommended that he be sentenced to 240 months in prison.3 The PSR made that recommendation by starting at a base offense level of 30, predicated on a drug weight of fifty-six grams. The offense level was then lowered to reflect Williams’s acceptance of responsibility, resulting in a final offense level of 27. With Williams’s criminal history category of VI, the Guidelines advised a sentencing range of 130 to 162 months. The prosecutor’s § 851 notice, however, triggered § 841(b)(l)(A)’s mandatory minimum sentence of 240 months. Because Williams’s entire advisory Guidelines range fell below the statutory mandatory 'minimum sentence, his Guidelines sentence was the statutory minimum of 240 months. See USSG § 5Gl.l(b) (“Where a statutorily required minimum sentence is greater than the maximum of the applicable guideline range, the statutorily required minimum sentence shall be the guideline sentence.”).

Prior to the December 9, 2008 sentencing hearing, the prosecutors filed a motion for a downward departure, pursuant to 18 U.S.C. § 3553(e), recognizing Williams’s substantial assistance to the authorities.4 [256]*256On the prosecutors’ recommendation, the court imposed a sentence of 180 months, reflecting a twenty-five percent reduction from the 240-month Guidelines sentence.

On May 9, 2012, more than three years after his conviction and sentencing, Williams filed a pro se motion for a sentence reduction under 18 U.S.C. § 3582(c)(2). The district court did not act on that motion until after the Probation Officer submitted a memorandum to the court on May 18, 2015, advising that Williams was eligible for a sentence reduction. On June 18, 2015, the court appointed a lawyer to represent Williams and ordered briefing on the sentence-reduction motion. Williams and the United States Attorney agreed that Williams was eligible for a sentence reduction under Guidelines Amendments 750 and 782 — both of which reduced the offense level applicable to his conviction — due to the procedural changes introduced by Guidelines Amendment 780. See USSG app. C, amend. 780 (Supp.2014) (revising Guidelines to clarify § 3582(c)(2) eligibility for defendant sentenced below statutory minimum due to substantial-assistance departure).

By memorandum opinion of July 10, 2015, the district court denied Williams’s § 3582(c)(2) motion. See United States v. Williams, No. 1:07-cr-00429 (M.D.N.C. July 10, 2015), ECF No. 372 (the “Opinion”). The Opinion acknowledged that, based on Amendments 750 and 782, Williams’s final offense level would be 21 instead of 27, resulting in a Guidelines range of 77 to 96 months. Nonetheless, the court ruled that Williams had not satisfied the eligibility requirements of § 3582(c)(2) because his 180-month sentence was based on a statutory mandatory minimum and a statutorily authorized departure for substantial assistance, rather than on a Guidelines range that had been subsequently lowered. The court reached that conclusion in reliance on our 2009 decision in United States v. Hood, 556 F.3d 226 (4th Cir.2009).

Williams filed a timely notice of appeal, and we possess jurisdiction pursuant to 28 U.S.C. § 1291 and 18 U.S.C. § 3742(a).

II.

We review de novo a district court’s ruling on the scope of its legal authority under 18 U.S.C. § 3582(c)(2). See United States v. Mann, 709 F.3d 301, 304 (4th Cir.2013).

III.

On appeal, Williams maintains that he is eligible for a sentence reduction under 18 U.S.C. § 3582(c)(2). The district court, in its Opinion denying Williams’s sentence-reduction motion, disagreed with that contention. The amicus counsel defends the position of the district court in this proceeding. Williams and the United States Attorney counter that the court misunderstood the scope of its authority under § 3582(c)(2), because, inter aha, Amendment 780, promulgated in 2014, revised the Sentencing Commission’s policy statement governing eligibility for a sentence reduction. As a result, they contend that the court’s denial of Williams’s § 3582(c)(2) motion should be vacated.

A.

In order to properly assess Williams’s eligibility for a sentence reduction under § 3582(c)(2), we first identify the relevant [257]*257principles governing such reductions. That discussion implicates the Supreme Court’s mandate that a federal court determine a prisoner’s eligibility under § 3582(c)(2) by adhering to the Commission’s policy statements, and also involves the Commission’s authority to dictate the proper application of the Guidelines.

1.

Congress created the Commission in 1984 to provide guidance, clarity, and fairness in sentencing. See 28 U.S.C. § 991(b). The Guidelines reflect the Commission’s efforts to that end and assist the federal courts in imposing appropriate sentences on a case-by-case basis. To ensure that the Guidelines reflect current views on criminal behavior and account for revisions to statutory provisions, Congress has empowered the Commission to amend the Guidelines. See id. § 994(o), (p).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Eunice Nkongho
107 F.4th 373 (Fourth Circuit, 2024)
United States v. Kevin Hewlett
Fourth Circuit, 2023
In re: Kenneth Graham
61 F.4th 433 (Fourth Circuit, 2023)
United States v. Omar Banks
29 F.4th 168 (Fourth Circuit, 2022)
Kevin Younger v. Neil Dupree
Fourth Circuit, 2022
United States v. Lenair Moses
23 F.4th 347 (Fourth Circuit, 2022)
Old Dominion Electric v. PJM Interconnection, LLC
24 F.4th 271 (Fourth Circuit, 2022)
United States v. Terrance Dennis
19 F.4th 656 (Fourth Circuit, 2021)
United States v. Antonio Simmons
9 F.4th 947 (Fourth Circuit, 2021)
United States v. Tevon Fayson
Fourth Circuit, 2021
United States v. Alicia Mooney
Fourth Circuit, 2019
United States v. Tony McCoy
Fourth Circuit, 2019

Cite This Page — Counsel Stack

Bluebook (online)
808 F.3d 253, 2015 WL 8603010, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-lance-williams-ca4-2015.