United States v. Padilla-Diaz

The Ninth Circuit affirmed the denial of defendants' motions for sentence reductions under United States Sentencing Guidelines Amendment 782 and 18 U.S.C. 3582(c)(2). The panel held that USSG 1B1.10(b)(2)(A) does not impermissibly conflict with 28 U.S.C. 991(b) and defendants have not shown that section 1B1.10(b)(2)(A) violates equal protection or due process. Under section 1B1.10(b)(2)(A), defendants who originally had lower sentences may be awarded the same sentences in section 3582(c)(2) proceedings as offenders who originally had higher sentences. Sentences that were initially tailored to avoid unwarranted disparities and to account for individualized circumstances will now converge at the low end of the amended guideline range. The panel explained that this anomalous result did not create an irreconcilable conflict with section 991(b). Furthermore, while section 1B1.10(b)(2)(A) will sometimes produce unequal and arguably unfair results, defendants have not shown that it fails rational basis review. As to due process, defendants' failure to receive a benefit from Amendment 782 was not a result of a retroactive deprivation of a pre-existing benefit. Rather, it was the result of a prospective grant of a limited benefit. View "United States v. Padilla-Diaz" on Justia Law