United States v. Leonard, No. 15-2232 (2d Cir. 2016)
Annotate this CaseIn 2008, Leonard pled guilty to conspiracies to distribute 100 or more kilograms of marijuana, 21 U.S.C. 841(a)(1), (b)(1)(B), 846; and to launder the proceeds of that illegal trafficking, 18 U.S.C. 1956(h). While serving a 114‐month prison term, Leonard unsuccessfully sought a sentence reduction under 18 U.S.C. 3582(c)(2). The court reasoned that an amended, retroactive, 97‐121‐month Sentencing Guidelines range was not lower than the 97-121‐month range agreed to in the Fed. R. Crim. P. 11(c)(1)(C) plea agreement. The Second Circuit reversed and remanded. Leonard is eligible for a section 3582(c)(2) sentence reduction because his original sentence was “based on” the Sentencing Guidelines as that statutory phrase was construed by the Supreme Court in 2011, but the extent of the reduction for which Leonard is eligible is narrower than he urges because his “applicable” Guidelines range, as defined by U.S.S.G. 1B1.10 was the 121‐151‐month range calculated by the district court before accepting what was effectively a downward variance to the 97‐121‐month range prescribed in the 11(c)(1)(C) agreement. Leonard is eligible for a reduction of his sentence, but to no less than 97 months’ incarceration.
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