United States v. Bryon Taylor

The majority concludes that Taylor’s appeal must fail, relying largely on this court’s prior decision in United States v. Hameed, 614 F.3d 259 (6th Cir.2010), for the proposition that Amendment 750 of the Sentencing Guidelines does not have the effect of lowering Taylor’s “applicable guideline range.” But times have changed since Hameed. Amendments 750 and 759 to the Guidelines took effect on November 1, 2011, retroactively lowering the crack-cocaine ranges in Guidelines § 2D1.1 and amending the policy statements. Under the new policy statements, a statutory minimum must “operate” or be…