(CN) – The Supreme Court ruled Monday that a defendant who takes a plea deal can get a lighter sentence if guidelines are changed later, but those who were sentenced based on mandatory minimums and their assistance to the government are not eligible for sentencing reductions if the guidelines are lowered.
Both cases, Koons v. U.S. and Hughes v. U.S., required a clarification of the U.S. Supreme Court’s 5-4 ruling in the 2011 decision Freeman v. U.S.
In Freeman, the court’s liberal wing, joined by Justice Anthony Kennedy, held that a defendant who enters into a plea agreement may be eligible for a sentence reduction if the sentencing guidelines are later reduced.
That ruling is complicated by Justice Sonia Sotomayor’s separate opinion concurring in the judgment, which states that a plea agreement must be expressly tied to the guidelines’ recommended range for a prisoner to later seek a sentence reduction.
In June 2014, the U.S. Sentencing Commission announced Amendment 782 to the sentencing guidelines, which reduced the offense level for specific drug offenses by two levels, to be applied retroactively.
The defendants in Koons v. U.S. were sentenced to between seven and 12 years in prison for conspiracy to manufacture and distribute meth.
They were denied a sentence reduction, however, because their initial sentences were below guidelines due to their having provided substantial assistance to the government.
Defendant Erik Hughes in Hughes v. U.S. pleaded guilty and was sentenced to 15 years in prison for conspiracy to distribute meth and being a felon in possession of a firearm.
He was denied a sentencing reduction based on a finding that his plea agreement was not tied to a sentencing guidelines range.
On Monday, the Supreme Court ruled 6-3 in Hughes that a defendant who enters into a criminal plea agreement is eligible for a sentence reduction if the sentencing guidelines range is later retroactively amended.
The majority noted that the district court accepted Hughes’ plea agreement and imposed a sentence that it deemed compatible with guidelines.
“Thus, the sentencing range was a basis for the sentence that the district court imposed. That range has ‘subsequently been lowered by the Sentencing Commission,’ so Hughes is eligible for relief,” Justice Anthony Kennedy wrote for the majority.
Chief Justice John Roberts dissented and was joined by Justices Clarence Thomas and Samuel Alito.
He argued that Hughes’ sentence was based on his plea deal, not the sentencing guidelines.
“If a defendant pleads guilty pursuant to a Type-C agreement specifying a particular term of imprisonment, the district court may sentence him only to that term,” Roberts wrote. “If the judge considers the parties’ chosen sentence to be inappropriate, he does not have discretion to impose a different one. Instead, the court’s only option is to reject the agreement and afford the defendant the opportunity to be released from his guilty plea.”
Roberts concluded, “Hughes pleaded guilty and entered into a binding agreement because he otherwise was looking at life in prison. Although the district court dutifully performed the required guidelines calculations, Hughes’s sentence was based on the agreement, not the guidelines range. Hughes should not receive a windfall benefit because that range has been changed.”
In Koons, the high court ruled unanimously Monday that an inmate who helped the government and was sentenced to a term below the mandatory minimum is not eligible for an even lower sentence, when the Sentencing Commission retroactively reduces the sentencing guidelines range for the applicable crimes.
Justice Samuel Alito delivered the opinion, writing that the defendants in the case were sentenced based on their mandatory minimums and assistance to the government, not on sentencing guidelines that were later lowered.
“Identically situated defendants sentenced today may receive the same sentences petitioners received, and those defendants, like petitioners, are not eligible for sentence reductions,” the ruling states.
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