United States v. Salazar – Do It For The Caselaw

Holding: The court affirmed the district court's order denying the motion for sentence reduction because Amendment eight hundred twenty-one does not apply to sentences imposed for supervised release revocations.
Standard: Abuse of discretion for the decision to reduce; de novo for the scope of legal authority.
Vote: Unpublished per curiam opinion affirming the district court.
Practical effect: Defendants seeking sentence reductions under Amendment eight hundred twenty-one cannot rely on that amendment to reduce sentences imposed specifically for supervised release revocations.

The Fourth Circuit affirmed a district court's denial of a sentence reduction motion under Section thirty-five eighty-two, subsection C, paragraph two. The court held that Amendment eight hundred twenty-one to the Sentencing Guidelines does not authorize reducing a sentence imposed for a supervised release revocation.

Background

Guillermo Alfonson Salazar appealed the district court’s order denying his motion for a sentence reduction pursuant to Amendment eight hundred twenty-one to the Sentencing Guidelines under Section thirty-five eighty-two, subsection C, paragraph two of Title eighteen of the United States Code.

The court’s reasoning

The court reviewed the district court’s decision for abuse of discretion regarding the reduction and de novo regarding the scope of legal authority. The court found no error in the record, concluding that the district court properly determined that Salazar’s revocation sentence could not be reduced under Amendment eight hundred twenty-one. The court cited Commentary note eight, subsection A, paragraph one of Section one point one point ten of the United States Sentencing Guidelines, which states that only a term of imprisonment imposed as part of an original sentence is authorized to be reduced under this section.

Our review of the record reveals no error.

United States v. Salazar, No. 25-6396 (4th Cir. Mar. 17, 2026)

What it means going forward

Defendants seeking sentence reductions under Amendment eight hundred twenty-one cannot rely on that amendment to reduce sentences imposed specifically for supervised release revocations.

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