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Koons v. United States

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Supreme Court of the United States
Koons v. United States
Term: 2017
Important Dates
Argument: March 27, 2018
Decided: June 4, 2018
Outcome
Eighth Circuit affirmed
Vote
9 - 0 to affirm
Majority
Chief Justice John G. Roberts • Anthony Kennedy • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch


Koons v. United States is a case argued during the October 2017 term of the U.S. Supreme Court. Argument in the case was held on March 27, 2018. The case came on a writ of certiorari to the United States Court of Appeals for the 8th Circuit.

HIGHLIGHTS
  • The case: Several defendants provided assistance to law enforcement. As part of their guilty pleas, the government requested and the court granted a reduction in their sentences as a result of that assistance. The reduction for assistance meant that they were sentenced to periods of imprisonment below the mandatory minimums for the crimes to which they pleaded guilty. After their pleas, the United States Sentencing Commission retroactively lowered the sentencing guidelines for the crimes for which they were convicted. The defendants requested a reduction in their sentences. On appeal, the United States Court of Appeals for the 8th Circuit ruled that they were not entitled to a reduction because the reductions they received in exchange for providing assistance were based on mandatory minimums, not on the sentencing guidelines.
  • The issue: Whether defendants who receive sentencing reductions from mandatory minimum sentences are eligible for further sentencing reductions if the sentencing guidelines for their convictions are retroactively reduced.[1]
  • The outcome: A unanimous Supreme Court affirmed the ruing of the Eighth Circuit, concluding that the defendants were not entitled to reductions.[2]


    • You can review the lower court's opinion here.[3]

    Background

    Legal question

    This was a case about the interaction between the U.S. Sentencing Commission's sentencing guidelines and mandatory minimum sentences. It was also about the interpretation of an earlier U.S. Supreme Court case, Freeman v. United States. The interpretation of Freeman was also at issue in another of this term's cases. See Hughes v. United States.

    Mandatory minimum sentences are imposed by law for particular crimes. However, courts are allowed to reduce a defendant's sentence in certain situations. For example, if a defendant provides substantial assistance to law enforcement, at the government's request the court may impose a sentence below the mandatory minimum. That reduction in sentencing is called a downward departure.[3]

    Separately, the United States Sentencing Commission issues sentencing guidelines. Those guidelines allow courts to calculate a sentencing score based on the defendant's actions, prior criminal history, and other circumstances and characteristics. Based on the defendant's score, the Guidelines provide a suggested sentencing range. Occasionally, the Commission will determine that a particular Guidelines range is too high and will lower it. Under 18 U.S.C. § 3582(c)(2), a court may retroactively reduce the sentence of “a defendant who has been sentenced to a term of imprisonment based on a sentencing range that has subsequently been lowered by the Sentencing Commission."[3]

    In Freeman v. United States, the U.S. Supreme Court considered whether a defendant is eligible for a sentencing reduction based on a retroactive guidelines revision if the defendant had originally received a sentencing reduction as part of a plea deal. A plurality of the court—four justices—ruled that defendants who received sentence reductions by entering into plea agreements are generally eligible for sentence reductions under § 3582(c)(2). An additional justice—Justice Sotomayor—agreed that the defendant in the case was eligible for a reduction but wrote separately to identify the circumstances under which she believed defendants who had accepted plea agreements would be eligible for sentencing reductions.[3]

    The question in this case was whether a defendant is eligible for a sentencing reduction under § 3582(c)(2) if he or she was originally sentenced based on a downward departure from the mandatory minimum rather than a downward departure from the relevant sentencing guidelines.[3]

    Case background

    Timothy Koons and several other defendants pleaded guilty to crimes involving methamphetamine. Those convictions were subject to mandatory minimum sentences. All of the defendants provided assistance to law enforcement. As a result of the assistance provided by the defendants, the government asked the court for substantial assistance downward departures from the mandatory minimums. In each case, the court granted a downward departure and imposed a sentence below the mandatory minimum. Additionally, in each case, the applicable sentencing guidelines specified a sentencing range that was below the mandatory minimum.[3]

    After the defendants were sentenced, the U.S. Sentencing Commission revised the sentencing guidelines that applied to the defendants. As a result of the revision, the applicable ranges for the defendants under the sentencing guidelines were lowered. The district court then considered whether the defendants were eligible for a sentencing reduction under § 3582(c)(2). The district court ruled that the defendants were not eligible because their original sentences had been based on mandatory minimums, not on the applicable sentencing guidelines.[3]

    Panel opinion

    On appeal, the United States Court of Appeals for the 8th Circuit affirmed the district court's ruling. The court wrote, "Defendants are eligible for discretionary § 3582(c)(2) reductions, the government argues, because § 3582(c)(2) authorizes a reduction based on a defendant’s substantial assistance if it is 'consistent with applicable policy statements issued by the Sentencing Commission.'" However, the court continued, that argument "ignores a critical 'threshold question' raised by the plain language of § 3582(c)(2), namely, whether each defendant was sentenced based on a sentencing range that has subsequently been lowered by the Sentencing Commission." In these cases, the court concluded, the defendants were sentenced using downward departures based on the mandatory minimum sentences, not on the Guidelines.[3]

    The court also ruled that its conclusion was supported and controlled by the United States Supreme Court's ruling in Freeman v. United States. The court concluded that Freeman required a link between a defendant's imposed sentence and the Guidelines in order for a defendant to be eligible for a sentencing reduction under § 3582(c)(2). The court continued:

    “ Congress has declared that the Commission’s guidelines and policy statements shall 'establish a sentencing range that is consistent with all pertinent provisions of title 18, United States Code.' But the Commission’s interpretation of § 3582(c)(2) ignores the statute’s plain text as construed in Freeman -- defendants’ sentences were 'based on' the mandatory minimum and their substantial assistance, not on a sentencing range that has subsequently been lowered by the Sentencing Commission. Once the Supreme Court determines the meaning of a statute, courts assess an agency’s later interpretation of the statute against that settled law. The Commission does not have the authority to amend a statute the Supreme Court has construed.[3][4][5] ”

    The defendants then appealed to the United States Supreme Court.

    Petitioner's challenge

    The petitioners, Timothy Koons and other defendants, challenged the holding of the United States Court of Appeals for the 8th Circuit. They argued that the Eighth Circuit erred in concluding that they were not entitled to sentencing reductions.[3]

    Certiorari granted

    On August 22, 2017, the petitioner initiated proceedings in the Supreme Court of the United States in filing a petition for a writ of certiorari to the United States Court of Appeals for the 8th Circuit. The U.S. Supreme Court granted the petitioner's request for certiorari on December 8, 2017. Argument in the case was held on March 27, 2018.[1]

    Question presented

    Question presented:

    "(1) Whether the Eighth Circuit Court of Appeals erred in holding, contrary to the opinion of the Fourth Circuit Court of Appeals, that defendants whose initial advisory guideline sentencing range was below a statutory mandatory minimum and who were subsequently sentenced below that minimum after the district court granted a government motion for reduction in sentence for substantial assistance pursuant to 18 U.S.C. § 3553(e), are not eligible for further reduction in sentence under 18 U.S.C. § 3582(c)(2) and retroactive sentencing guideline Amendment 782, which lowered the base offense levels assigned to most drug quantities?
    (2) Whether Freeman v. United States, 564 U.S. 522 (2011) (plurality opinion) supports the holding that there is a substantive limitation on the term 'based on' in 18 U.S.C. § 3582(c)(2) that prohibits defendants whose initial advisory guideline range was below a statutory mandatory minimum, and who were subsequently sentenced below that minimum after the district court granted a government motion for reduction in sentence for substantial assistance pursuant to 18 U.S.C. § 3553(e), from being eligible for further reduction in sentence due to retroactive sentencing guideline Amendment 782?"[1]

    Audio

    • Audio of oral argument:[6]



    Transcript

    • Transcript of oral argument:[7]

    Outcome

    Decision

    The Supreme Court unanimously affirmed the Eighth Circuit, ruling that the defendants were not entitled to sentencing reductions.[2]

    Opinion of the court

    Justice Samuel Alito wrote the opinion for a unanimous court. Alito ruled, "We hold that petitioners’ sentences were 'based on' their mandatory minimums and on their substantial assistance to the Government, not on sentencing ranges that the Commission later lowered. Petitioners are therefore ineligible for §3582(c)(2) sentence reductions."[2]

    Alito wrote that the advisory sentencing guidelines "can be overridden by other considerations . . . This is what happened here." In these cases, he continued, the sentencing trial courts had "discarded the advisory ranges in favor of the mandatory minimum sentences." Alito continued:

    “ Their sentences were not 'based on” the lowered Guidelines ranges because the District Court did not consider those ranges in imposing its ultimate sentences. On the contrary, the court scrapped the ranges in favor of the mandatory minimums, and never considered the ranges again; as the court explained, the ranges dropped out of the case. And once out of the case, the ranges could not come close to forming the “basis for the sentence that the District Court imposed,” and petitioners thus could not receive §3582(c)(2) sentence reductions.[2][5] ”

    Text of the opinion

    See also

    Footnotes

    1. ↑ 1.0 1.1 1.2 Supreme Court of the United States, "'Koons v. United States' Question Presented," December 8, 2017
    2. ↑ 2.0 2.1 2.2 2.3 United States Supreme Court, "Koons v. United States opinion," June 4, 2018
    3. ↑ 3.0 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 United States Court of Appeals for the 8th Circuit, "'Koons v. United States' Opinion," March 10, 2017
    4. ↑ Internal citations and quotations omitted.
    5. ↑ 5.0 5.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, Koons v. United States, argued March 27, 2018
    7. ↑ Supreme Court of the United States, Koons v. United States, argued March 27, 2018
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