Friday, November 15th, 2013

District Court Did Not Adequately Explain Refusal to Reduce Sentence

United States v. Christie, No. 13-245-cr (2d Cir. Nov. 15, 2013) (Lynch, Chin, and Droney), available here

Defendant moved for a sentence reduction under 18 U.S.C. 3582(c)(2), based on the 2011 Amendments to the Sentencing Guidelines lowering the penalties for crack cocaine offenses. Both the Probation Office and the government agreed that the defendant was eligible for a reduction. But the government argued that the court should decline to reduce the sentence because of the defendant’s firearms offenses and criminal history.
The district court entered an order that stated only that the defendant’s motion was “denied.” The court did not explain the reasons for its decision. 
The Circuit held that the court’s failure to explain its decision made meaningful appellate review impossible. The Circuit noted that the defendant’s sentence was above the now-applicable Guidelines range and that nothing in the record revealed why an above-Guidelines sentence was warranted. Because “at least some minimal statements of reasons for a court’s action on a [section] 3582(c)(2) motion is required,” the Circuit remanded for further proceedings.      
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