Supreme Court Issues Two New Decisions

Today the United States Supreme Court issued two decisions that can have a significant impact on a large number of current federal inmates. In Hughes v. United States, the Court addressed the issue of whether a federal inmate who enters a plea pursuant to Federal Rule of Criminal Procedure 11(c)(1)(C) can seek to be re-sentenced pursuant to 18 U.S.C. 3582(c)(2) when the Sentencing Commission makes an amendment that subsequently lowers the guideline range. A plea under FRCP 11(c)(1)(C), although not commonly utilized, is a specific agreement between the government and the defendant to a specific defined sentence and, if accepted by the court, that specified sentence must be imposed by the court leaving the court no discretion. The Hughes decision makes it clear that a federal inmate even with a FRCP 11(c)(1)(C) plea has a right to be re-sentenced if the applicable guideline range is subsequently reduced. This is great news for about 800 federal inmates anticipated to be affected by this decision.

In a similar case, Koons v. United States, the court decided whether defendants subject to statutory mandatory minimum sentences, but who received prison terms below the minimum because they provided substantial assistance to the government, are eligible for reductions under 18 U.S.C. §3582(c)(2). The court held that these type of federal inmates are NOT entitled for a re-sentencing under 18 U.S.C. §3582(c)(2).

If you have any questions or may need or assistance, please contact National Prison & Sentencing Consultants (NPSC) at [email protected] or at 615-696-6153.