United States v. Taylor, No. 13-3015 (D.C. Cir. 2014)
Annotate this CaseIn 2009, defendant was sentenced to 180 months in prison for conspiracy to distribute and possess with intent to distribute 50 grams or more of crack cocaine. In 2011, the Sentencing Commission gave retroactive effect to an amendment to the Sentencing Guidelines lowering base offense levels for offenses involving crack cocaine. The court joined its sister circuits in upholding U.S.S.G. 1B1.10 as a lawful exercise of the Sentencing Commission's powers. Because U.S.S.G. 1B10(b)(2)(A) barred sentencing reductions below the applicable amended guideline range, and because defendant's sentence was already below that range, the district court properly held that a reduction in his sentence was unavailable. Accordingly, the court affirmed the judgment of the district court, rejecting defendant's challenge to the validity of U.S.S.G. 1B10(b)(2)(A).
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