Background
Shane Seizys entered a binding plea agreement in two thousand and sixteen to plead guilty to two counts of robbery and one count of brandishing a firearm during a crime of violence. In exchange for dismissing thirteen other counts, he agreed to a total sentence of three hundred forty-eight months. The district court accepted the plea and imposed consecutive sentences totaling that term. In two thousand and twenty-four, Seizys moved for a sentence reduction after a retroactive amendment to the U.S. Sentencing Guidelines lowered his criminal history category. The district court denied the motion, and Seizys appealed.
The court’s reasoning
Under Section thirty-five eighty-two subsection two, a defendant is eligible for a sentence reduction only if the sentence was based on a Guidelines range that was subsequently lowered. The Supreme Court has held that a sentence imposed under a binding plea agreement is not excepted from this rule, but relief is unavailable if the Guidelines range was not a relevant part of the analytical framework used to determine the sentence. The Eighth Circuit found that the district court’s decision was driven by the need to avoid a mandatory life sentence resulting from stacked firearm charges, not the Guidelines range. Although the agreed sentence was close to the Guidelines range, the court determined that the agreement to avoid the mandatory minimum was the foundation of the sentence.
What it means going forward
Defendants bound by plea agreements that prioritize avoiding mandatory minimums over Guidelines calculations may be ineligible for sentence reductions even if their agreed sentence is numerically close to the Guidelines range.