United States v. Leandre Watkins

BOGGS, Circuit Judge.

When Leandre Watkins was sentenced on convictions for possession with intent to distribute cocaine base and being a felon in possession of a firearm, the district court granted a downward departure on the view that his criminal-history category overrepresented the seriousness of his past offenses. A year later, Amendment 782 to the federal sentencing guidelines reduced the base offense level for Watkins’s drug crime. The district court found that it was nonetheless prohibited from reducing Watkins’s term of imprisonment because the original sentence was at the low end of…