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United States v. Wanton

Citations: 525 F.3d 621; 2008 U.S. App. LEXIS 9717; 2008 WL 1959259Docket: 08-1813

Court: Court of Appeals for the Eighth Circuit; May 7, 2008; Federal Appellate Court

Narrative Opinion Summary

Chucky L. Wanton appeals the district court's denial of his motion to reduce his sentence under 18 U.S.C. § 3582(c)(2), referencing Amendment 706 of the U.S. Sentencing Guidelines, which adjusted base offense levels for certain quantities of crack cocaine. Wanton had pled guilty to distributing over 50 grams of crack and was sentenced to 135 months imprisonment on September 25, 2006. His motion for reduction, filed in December 2007, was denied because his relevant conduct involved over 4.5 kilograms of crack, a quantity that is not eligible for a reduction under the new amendment. Consequently, his offense level and guideline range remained unchanged, leaving his original sentence intact. The Eighth Circuit Court of Appeals affirmed the district court’s decision, citing that the amendment did not apply to Wanton’s case.

Legal Issues Addressed

Affirmation by the Eighth Circuit Court of Appeals

Application: The appellate court affirmed the district court's decision, supporting the interpretation that the amendment did not apply to sentences involving quantities exceeding the amendment's thresholds.

Reasoning: The Eighth Circuit Court of Appeals affirmed the district court’s decision, citing that the amendment did not apply to Wanton’s case.

Application of U.S. Sentencing Guidelines Amendment 706

Application: Amendment 706 adjusted the base offense levels for certain quantities of crack cocaine, but does not apply if the quantity involved exceeds the thresholds set by the amendment, thus leaving the original sentence intact.

Reasoning: Wanton had pled guilty to distributing over 50 grams of crack and was sentenced to 135 months imprisonment on September 25, 2006.

Sentence Reduction Under 18 U.S.C. § 3582(c)(2)

Application: The legal principle allows for sentence reduction if the sentencing range has been subsequently lowered by the Sentencing Commission. However, it does not apply if the defendant's offense level and guideline range remain unchanged under the amendment.

Reasoning: His motion for reduction, filed in December 2007, was denied because his relevant conduct involved over 4.5 kilograms of crack, a quantity that is not eligible for a reduction under the new amendment.