Sentencing Under Guideline Ranges Upheld in Supreme Court
Koons v. United States. No. 17-5716
Case History Regarding Sentencing
The petitioners in Koons v. United States had committed crimes that invoked the use of the mandatory minimums. through the guideline ranges. Their sentences were based on these ranges. Each of them provided information to the government that assisted in the investigation and prosecution of a case.
As a result, the prosecutor filed for reduction motions that resulted in sentences below the mandatory minimums. The court did not consider the guideline ranges on the case. This was due, in part, because the court discarded those when the court sentenced the petitioners to the mandatory minimums.
Later, the sentencing commission approved Amendment 782, which retroactively reduced the sentencing guidelines. This allowed a proportional reduction in sentence for those convicted under the advisory guidelines. In this case, the petitioners claimed they should be eligible for a sentence reduction. The court said that the petitioners would have to prove that their sentence was based on a sentence that was “based on” the guidelines. Unable to do so, their motions were denied.
Writing for the court, Justice Alito held that petitioners do not qualify for sentence reductions under §3582(c)(2) because their sentences were not “based on” their lowered guidelines ranges. Instead, their sentences were “based on their mandatory minimums and on their substantial assistance to the government."
Sentencing Guidelines vs. Mandatory Minimums
The court noted the ruling in Hughes “for a sentence to be “based on” a lowered guideline range, the range must have at least played “a relevant part [in] the framework the [sentencing] judge used” in imposing the sentence,” Yet, “when the range play no relevant part in the judge’s determination of the defendant’s ultimate sentence, the resulting sentence is not based on a guidelines range.”
Here, the guideline ranges played no part in their sentences because “the ranges play[ed] no relevant part in the judge’s determination of the defendant’s ultimate sentence.” Therefore, the guideline ranges were discarded for the mandatory minimums.
The court also noted in response to the petitioners argument that “what matters, instead, is the role that the guideline range played in the selection of the sentence eventually imposed, not the role that the range played in the initial calculation. And here, while consideration of the ranges may have served as the “starting point” in the sense that the court began by calculating those ranges, the ranges clearly did not form the “foundation” of the sentences ultimately selected.”
Conclusion: Sentence Upheld
The Supreme Court affirmed the decision of the appellate court, denying the petitioner’s motions. Koons v. United States.
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