United States v. Brown

[PUBLISHED]

Steven W. Brown appeals following the district court’s 2 grant of his motion for a reduction in sentence pursuant to 18 U.S.C. § 3582(c)(2) and the 2008 Guidelines amendments, which retroactively reduce base offense levels for particular offenses involving cocaine base. The district court reduced Brown’s offense level by two levels, yielding a modified Guidelines range of 324 to 405 months’ imprisonment, and sentenced Brown to the bottom of the modified Guidelines range. Brown argues that the district court erroneously applied the Guidelines as mandatory in resentencing him…