United States v. Mannie

971 F.3d 1145
CourtCourt of Appeals for the Tenth Circuit
DecidedAugust 18, 2020
Docket19-6102
StatusPublished
Cited by51 cases

This text of 971 F.3d 1145 (United States v. Mannie) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth 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. Mannie, 971 F.3d 1145 (10th Cir. 2020).

Opinion

FILED United States Court of Appeals PUBLISH Tenth Circuit

UNITED STATES COURT OF APPEALS August 18, 2020

Christopher M. Wolpert FOR THE TENTH CIRCUIT Clerk of Court _________________________________

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v. No. 19-6102

ARTHUR MORRIS MANNIE, JR.,

Defendant - Appellant.

–––––––––––––––––––––––––––––––––––

v. No. 19-6111

MICHAEL DEWAYNE MAYTUBBY,

Defendant - Appellant. _________________________________

Appeal from the United States District Court for the Western District of Oklahoma (D.C. Nos. 5:09-CR-00289-F-1 and 5:06-CR-00136-R-1) _________________________________

Susan M. Otto, Federal Public Defender (Paul Antonio Lacy, Assistant Federal Public Defender, with her on the brief), Oklahoma City, Oklahoma for Defendants-Appellants.

Timothy W. Ogilvie, Assistant United States Attorney (Timothy J. Downing, United States Attorney, with him on the brief), Oklahoma City, Oklahoma, for Plaintiff- Appellee. _________________________________ Before HARTZ, EBEL, and MATHESON, Circuit Judges. _________________________________

EBEL, Circuit Judge. _________________________________

To alleviate some of the impacts caused by the statutory sentencing disparity

between crack cocaine and powder cocaine offenses, Congress passed the Fair

Sentencing Act of 2010 (“2010 FSA”) which, among other things, increased the

quantity of crack cocaine required to trigger certain statutory penalties. In 2018,

Congress passed the First Step Act (“2018 FSA”), which, inter alia, made the Fair

Sentencing Act’s benefits retroactively applicable to offenders who committed

offenses prior to the 2010 FSA’s effective date of August 3, 2010.

We have consolidated these appeals for the purpose of disposition, and we

address the requirements for reducing an offender’s sentence under section 404 of the

2018 FSA. We hold that an offender is eligible to seek relief under the 2018 FSA if

he or she was convicted of and sentenced for (1) a violation of a federal criminal

statute, (2) the statutory penalties for which were modified by section 2 or 3 of the

2010 FSA, and (3) that was committed prior to August 3, 2010. We further hold that

our review of the district court’s action on a 2018 FSA motion is for an abuse of

discretion, the same as other post-trial motions. Finally, we hold that when presented

with a 2018 FSA motion for a reduced sentence, the court need not, but may in its

discretion, hold a hearing on the motion.

Arthur Morris Mannie, Jr., and Michael Dewayne Maytubby moved the district

court for reductions in their sentences pursuant to the 2018 FSA. The district court

2 declined to reduce either sentence; both Mannie and Maytubby appealed. Applying

today’s holdings to the cases at bar, we AFFIRM the district court’s order denying

Mannie’s motion for sentence modification, and we DISMISS Maytubby’s appeal for

lack of standing.

I. BACKGROUND

A. Sentence Modification and the First Step Act of 2018

In general, once a court has imposed a sentence, the court has no authority to

modify that sentence. However, that is not an absolute rule; Congress has provided

the court with the authority to modify previously imposed sentences in three, very

limited circumstances. The court’s authority to modify a sentence, and the

limitations of that authority, is set forth in 18 U.S.C. § 3582(c). One such exception

permits a court to modify a previously imposed sentence when a modification is

“expressly permitted by statute or by Rule 35 of the Federal Rules of Criminal

Procedure.”1 § 3582(c)(1)(B).

The specific authority for that exception is found in § 3582(c)(1)(B), which

authorizes the court to implement modifications as directed by statute (or Federal

Rule of Criminal Procedure 35):

(c) Modification of an imposed term of imprisonment.--The court may not modify a term of imprisonment once it has been imposed except that-- (1) in any case--

1 The other two exceptions are when there are certain extraordinary and compelling circumstances, § 3582(c)(1)(A), and when a revision to the U.S.S.G. has lowered the sentencing range on which an offender’s sentence was based, § 3582(c)(2). Neither exception is applicable here. 3 ... (B) the court may modify an imposed term of imprisonment to the extent otherwise expressly permitted by statute or by Rule 35 of the Federal Rules of Criminal Procedure[.]

While this exception authorizes the court to implement modifications, it does not

itself provide standards for those modification. Thus, § 3582(c)(1)(B)’s authorization

alone is not sufficient—the court must look elsewhere to find another statute

containing said standards. In this case, those statutes are the Fair Sentencing Act of

2010 and the First Step Act of 2018.

In 2010, the statutory sentencing guidelines for drug offenses included a 100-

to-1 ratio between sentences imposed for crack cocaine and those imposed for

powder cocaine. There was a growing concern that this disparity was unjustified by

the differences between the two forms of cocaine, and that it was discriminatory

because it led to much higher sentences for offenses dealing with crack cocaine than

those dealing with powder cocaine. Congress sought to reduce that disparity in two

separate statutes, beginning with the Fair Sentencing Act of 2010. Pub L. No. 111-

220, 124 Stat. 2372.

The 2010 FSA in part reduced the disparity for sentences imposed after the

effective date of that statue by increasing the quantities of crack cocaine required to

subject an offender to a mandatory minimum sentence, id. § 2, and by eliminating the

mandatory minimum sentence for simple possession, id. § 3. Had that statute been in

effect when Mannie and Maytubby were convicted, it would have led to significantly

reduced sentences for both of them. However, Congress did not make the 2010

4 FSA’s sentencing adjustment retroactive, and the Supreme Court has never held it to

be so.

Congress rectified that inequity when it enacted the First Step Act of 2018,

which retroactively applied the new crack cocaine quantity thresholds to those

offenders who were sentenced prior to the 2010 FSA’s effective date.2 As the

language in the 2018 FSA is short and important to our decision here, we lay it out in

full:

SEC. 404. APPLICATION OF FAIR SENTENCING ACT.

(a) DEFINITION OF COVERED OFFENSE.—In this section, the term “covered offense” means a violation of a Federal criminal statute, the statutory penalties for which were modified by section 2 or 3 of the Fair Sentencing Act of 2010, that was committed before August 3, 2010.

(b) DEFENDANTS PREVIOUSLY SENTENCED.—A court that imposed a sentence for a covered offense may, on motion of the defendant, the Director of the Bureau of Prisons, the attorney for the Government, or the court, impose a reduced sentence as if sections 2 and 3 of the Fair Sentencing Act of 2010 were in effect at the time the covered offense was committed.

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