United States v. Martin

Martin pleaded guilty to possession with intent to distribute more than 50 grams of crack cocaine, 21 U.S.C. 841(a)(1); (b)(1)(B)(iii). The parties agreed that Martin’s advisory Guidelines range was 70-87 months’ imprisonment and that a sentence of 87 months was appropriate. According to the Probation Office, Martin’s Guidelines range was 188-235 months’ because Martin was a career offender. At sentencing, the district court stated that Martin was a career offender, noting crimes of aggravated assault, resisting arrest, and fleeing a police officer. After considering the 18 U.S.C. 3553 factors, the Court sentenced Martin to 87 months’ imprisonment. Martin did not appeal. In 2014, the Sentencing Commission promulgated Guidelines Amendment 782, retroactively reducing the base offense for many drug quantities, including the drug quantity associated with Martin’s offense. Martin sought a reduction of sentence under 18 U.S.C. 3582(c)(2), citing Amendment 782. The district court found him ineligible for relief because his Guidelines range was based on his status as a career offender rather than the drug quantity. The Third Circuit affirmed. Martin’s status as a career offender meant that he was not eligible for a reduced sentence. View "United States v. Martin" on Justia Law