The United States Court of Appeals for the Fourth Circuit affirmed a district court order denying a defendant's motion for sentence reduction. The court held that the defendant was ineligible for relief under Amendment Eight Hundred Twenty-One because his sentence was governed by mandatory minimums rather than his criminal history score.
Larry Barnes, Jr., proceeding pro se, appealed the district court’s order denying his renewed motion for a sentence reduction. The motion was filed pursuant to Section Thirty-Five Eighty-Two, subsection C, paragraph Two of Title One of the United States Code, seeking relief based on Amendment Eight Hundred Twenty-One to the Sentencing Guidelines.
The court’s reasoning
The court concluded that the district court correctly found the appellant ineligible for relief. The ineligibility stemmed from the fact that the original sentence was governed by mandatory minimum sentences rather than the defendant’s criminal history score.
What it means going forward
This decision clarifies that defendants whose sentences are anchored by statutory mandatory minimums cannot utilize Amendment Eight Hundred Twenty-One to seek reductions based on retroactive guideline changes.
