Background
The appellant, Oluwadamilare Kolaogunbule, appealed a district court order denying his motion for a sentence reduction under Section eighteen U.S.C. thirty-five eighty-two subsection C two. He argued the district court erred by not providing a reason for the denial in its written order.
The court’s reasoning
The court noted that while a district court may reduce a sentence if the original sentencing range was lowered by the Sentencing Commission, the statute authorizes only a limited adjustment. In the Fourth Circuit, there is a presumption that the district court sufficiently considered relevant factors when denying a motion under this section. The court found that the district court had explained its reasons at a hearing attended by the defendant’s counsel. Furthermore, the appellant failed to rebut the presumption that the court considered relevant factors.
Pursuant to 18 U.S.C. § 3582, a court generally may not modify a sentence once it has been imposed.
United States v. Melvin, 105 F.4th 620, 623 (4th Cir. 2024)
What it means going forward
The decision reinforces the limited scope of sentence reductions under Section eighteen U.S.C. thirty-five eighty-two subsection C two and upholds the presumption that district courts properly consider relevant factors in these proceedings.