United States v. Stith & Brantley, No. 11-4933 (2d Cir. 2013)
Annotate this CaseDefendants appealed from two orders by the district court which reduced their terms of imprisonment under 18 U.S.C. 3582(c)(2), but declined to depart or vary in any respect from defendants' amended guidelines range. At issue was whether U.S.S.G. 1B1.10(b)(2)(A) constituted a valid exercise of the Sentencing Commission's authority, and thus bound district courts whenever they reduced a defendant's sentence under section 3582(c)(2); and whether, even if section 1B1.10(b)(2)(A) bound district courts, it nonetheless permitted them to depart from a defendant's amended guideline range under U.S.S.G. 4A1.3. The court held that section 1B1.10(b)(2)(A) prohibited the district court from departing or varying from defendants' amended guidelines ranges, and that the scope of this prohibition included departures under U.S.S.G. 4A1.3. Accordingly, the court affirmed the judgment.
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