NACDL - Chavez-Meza v. United States

Amicus Brief

Brief of National Association of Criminal Defense Lawyers and National Association of Federal Defenders as Amici Curiae in Support of Petitioner.

Brief filed: 03/05/2018

Documents

Chavez-Meza v. United States

United States Supreme Court; Case No. 17-5639

Prior Decision

Decision below 854 F.3d 655 (10th Cir. Apr. 14, 2017)

Argument

The denial of a proportional sentence reduction without explanation undermines the purpose of Section 3582(c)(2) and the sentencing regime. Section 3582(c)(2) is intended to remedy “systemic injustice” and to provide “systemic relief.” In practice, courts typically grant proportional reductions and provide reasons when they do not. Denials of proportional reductions without explanation create an appearance of arbitrariness. The anchoring weight of the Guidelines requires district courts to explain decisions to deny proportional reductions. The Guidelines range anchors the court’s weighing of the Section 3553(a) factors at original sentencing. A revised Guidelines range anchors the court’s weighing of the Section 3553(a) factors in deciding a sentence-reduction motion. The depth of reasoning will depend on the circumstances, but no reasoning is not enough.

Author(s)

Amy Mason Saharia, Matthew J. Greer, and Caleb Seeley, Williams & Connolly LLP, Washington, DC; Barbara E. Bergman, NACDL, Tucson, AZ.