Chavez-Meza v. United States, 585 U.S. ___ (2018)
Petitioner pleaded guilty to possessing methamphetamine with intent to distribute. The judge determined the Guidelines range to be 135-168 months and imposed a 135-month sentence. The Sentencing Commission later lowered the relevant range to 108-135 months. Petitioner sought a sentence reduction under 18 U.S.C. 3582(c)(2). The same judge reduced his sentence to 114 months. The order certified that the judge had “tak[en] into account” the 18 U.S.C. 3553(a) factors and the Guidelines policy statement. Petitioner argued judge did not adequately explain why he rejected petitioner’s request for a 108-month sentence. The Tenth Circuit and the Supreme Court affirmed. Even assuming the court had a duty to explain its reasons when modifying petitioner’s sentence, what the court did was sufficient. The Court rejected an argument that a court must explain its reasoning in greater detail when it imposes a “disproportionate” sentence reduction—when the court reduces the prisoner’s sentence to a different point in the amended Guidelines range than the court previously selected in the original range. Because the record suggests the judge originally believed that 135 months was an appropriately high sentence in light of petitioner’s offense, it is unsurprising that he subsequently imposed a sentence somewhat higher than the bottom of the reduced range. Given the judge’s awareness of the arguments, his consideration of the relevant sentencing factors, and the intuitive reason why he picked a sentence above the very bottom of the new range, his explanation fell within the scope of a sentencing judge's lawful professional judgment.
Because the record as a whole demonstrated that the judge had a reasoned basis for his decision, the judge’s explanation for petitioner’s sentence reduction was adequate.
SUPREME COURT OF THE UNITED STATES
Syllabus
Chavez-Meza v. United States
certiorari to the united states court of appeals for the tenth circuit
No. 17–5639. Argued April 23, 2018—Decided June 18, 2018
The Federal Sentencing Guidelines require a sentencing judge to first identify the recommended Guidelines sentencing range based on certain offender and offense characteristics. The judge might choose a penalty within that Guidelines range, or the judge may “depart” or “vary” from the Guidelines and select a sentence outside the range. See United States v. Booker, 543 U. S. 220, 258–265. Either way, the judge must take into account certain statutory sentencing factors, see 18 U. S. C. §3553(a), and must “state in open court the reasons for [imposing] the particular sentence,” §3553(c). But when it comes to how detailed that statement of reasons must be, “[t]he law leaves much . . . to the judge’s own professional judgment.” Rita v. United States, 551 U. S. 338, 356. The explanation need not be lengthy, especially where “a matter is . . . conceptually simple . . . and the record makes clear that the sentencing judge considered the evidence and arguments.” Id., at 359.
Here, petitioner pleaded guilty to possessing methamphetamine with intent to distribute. The judge reviewed the Guidelines, determined the range to be 135 to 168 months, and imposed a sentence at the bottom of the range. The Sentencing Commission later lowered the relevant range to 108 to 135 months, and petitioner sought a sentence reduction under §3582(c)(2). Petitioner asked the judge to reduce his sentence to the bottom of the new range, but the judge reduced petitioner’s sentence to 114 months instead. The order was entered on a form certifying that the judge had “considered” petitioner’s “motion” and had “tak[en] into account” the §3553(a) factors and the relevant Guidelines policy statement. On appeal, petitioner argued the sentencing judge did not adequately explain why he rejected petitioner’s request for a 108-month sentence. The Court of Appeals affirmed.
Held: Because the record as a whole demonstrates the judge had a reasoned basis for his decision, the judge’s explanation for petitioner’s sentence reduction was adequate. Pp. 5–10.
(a) The Government argues petitioner was not entitled to an explanation at all because the statute governing sentence-modification motions does not expressly require a sentencing judge to state his reasons for imposing a particular sentence. See §3582(c)(2). It is unnecessary to go as far as the Government urges, however, because, even assuming the District Court had a duty to explain its reasons when modifying petitioner’s sentence, what the court did here was sufficient. Pp. 5–6.
(b) Petitioner contends that a district court must explain its reasoning in greater detail when the court imposes a “disproportionate” sentence reduction—that is, when the court reduces the prisoner’s sentence to a different point in the amended Guidelines range than the court previously selected in the original Guidelines range. That argument is unconvincing. As a technical matter, determining “proportionality” may prove difficult when the sentence is somewhere in the middle of the range. More importantly, the choice among points on the Guidelines range often reflects the belief that the chosen sentence is the “right” sentence based on various factors, including those found in §3553(a). If the applicable Guidelines range is later reduced, it is unsurprising that the sentencing judge may choose a non-proportional point in the new range. Pp. 6–7.
(c) Even assuming that a judge reducing a prisoner’s sentence must satisfy the same explanation requirement that applies at an original sentencing, the District Court’s explanation was adequate. At the original sentencing, petitioner asked for a downward variance from the Guidelines range, which the judge denied. The judge observed that petitioner’s sentence was high because of the destructiveness of methamphetamine and the quantity involved. The record from the original sentencing was before the judge—the same judge who imposed the original sentence—when he considered petitioner’s sentence-modification motion. By entering the form order, the judge certified that he had “considered” petitioner’s “motion” and had “tak[en] into account” the §3553(a) factors and the relevant Guidelines policy statement. Because the record as a whole suggests the judge originally believed that 135 months was an appropriately high sentence in light of petitioner’s offense conduct, it is unsurprising that he considered a sentence somewhat higher than the bottom of the reduced range to be appropriate as well. That is not to say that a disproportionate sentence reduction never may require a more detailed explanation. But given the simplicity of this case, the judge’s awareness of the arguments, his consideration of the relevant sentencing factors, and the intuitive reason why he picked a sentence above the very bottom of the new range, his explanation fell within the scope of lawful professional judgment that the law confers upon the sentencing judge. Pp. 7–10.
854 F. 3d 655, affirmed.
Breyer, J., delivered the opinion of the Court, in which Roberts, C. J., and Thomas, Ginsburg, and Alito, JJ., joined. Kennedy, J., filed a dissenting opinion, in which Sotomayor and Kagan, JJ., joined. Gorsuch, J., took no part in the consideration or decision of the case.
The record from the U.S.C.A. 10th Circuit has been returned. |
JUDGMENT ISSUED. |
Adjudged to be AFFIRMED. Breyer, J., delivered the opinion of the Court, in which Roberts, C. J., and Thomas, Ginsburg, and Alito, JJ., joined. Kennedy, J., filed a dissenting opinion, in which Sotomayor and Kagan, JJ., joined. Gorsuch, J., took no part in the consideration or decision of the case. |
Argued. For petitioner: Todd A. Coberly, Santa Fe, N. M. (Appointed by this Court.) For respondent: Rod J. Rosenstein, Deputy Attorney General, Department of Justice, Washington, D. C. |
Reply of petitioner Adaucto Chavez-Meza filed. (Distributed) |
Record received from the U.S.C.A. 10th Circuit. (1 Envelope) |
Record requested from the U.S.C.A.10th Circuit. |
Brief of respondent United States filed. (Distributed) |
Motion for leave to file Volume II of the joint appendix under seal GRANTED. Justice Gorsuch took no part in the consideration or decision of this motion. |
CIRCULATED |
DISTRIBUTED for Conference of 3/23/2018. |
Brief amicus curiae of Center on the Administration of Criminal Law filed. |
Motion to appoint counsel filed by petitioner GRANTED, and Todd A. Coberly, Esquire, of Santa Fe, New Mexico, is appointed to serve as counsel for the petitioner in this case. Justice Gorsuch took no part in the consideration or decision of this motion. |
Brief amici curiae of National Association of Criminal Defense Lawyers and National Association of Federal Defenders filed. (Distributed) |
Blanket Consent filed by Petitioner, Adaucto Chavez-Meza |
Brief of petitioner Adaucto Chavez-Meza filed (to be corrected and reprinted). |
Motion for leave to file Volume II of the joint appendix under seal filed by petitioner Adaucto Chavez-Meza. |
Joint appendix (Volume 1) filed. |
Brief of petitioner Adaucto Chavez-Meza filed (Corrected brief received 3/26/18). (Distributed) |
SET FOR ARGUMENT on Monday, April 23, 2018. |
DISTRIBUTED for Conference of 3/2/2018. |
Motion to appoint counsel filed by petitioner Adaucto Chavez-Meza. |
Motion to proceed in forma pauperis and petition for a writ of certiorari GRANTED. Justice Gorsuch took no part in the consideration or decision of this petition. |
DISTRIBUTED for Conference of 1/12/2018. |
DISTRIBUTED for Conference of 1/5/2018. |
Reply of petitioner Adaucto Chavez-Meza filed. |
Brief of respondent United States in opposition filed. |
Order further extending time to file response to petition to and including November 17, 2017. |
Order extending time to file response to petition to and including October 18, 2017. |
Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due September 18, 2017) |
Application (17A45) granted by Justice Sotomayor extending the time to file until August 14, 2017. |
Application (17A45) to extend the time to file a petition for a writ of certiorari from July 13, 2017 to August 14, 2017, submitted to Justice Sotomayor. |
Prior History
- United States v. Chavez-Meza, No. 16-2062 (10th Cir. Apr. 14, 2017)
Adaucto Chavez-Meza pleaded guilty to drug conspiracy charges in 2013. He originally received a prison sentence of 135 months, the Sentencing Guidelines minimum. In 2014, the Sentencing Commission amended the Guidelines to reduce the relevant offense levels. Chavez-Meza then sought and was granted a sentence reduction to 114 months, the minimum under the revised guidelines range. In confirming the new sentence, the district court issued a form order stating it had “tak[en] into account the policy statement set forth at USSG sec. 1B1.10 and the sentencing factors set forth in 18 U.S.C. 3553(a).” Chavez-Meza appealed his reduced sentence, claiming the district court erred by failing to adequately explain how it applied the section 3553(a) factors in imposing a 114-month sentence. Finding no reversible error in the district court's sentence calculation, the Tenth Circuit affirmed. Section 3582(c)(2) does not require additional explanation when a district court imposes a guidelines sentence and affirmatively states that it considered the section 3553(a) factors in its decision.