United States v. Stirling Michael Heaton

COLLOTON, Circuit Judge.

The government appeals an order of the district court reducing Stirling Heaton's term of imprisonment in light of Amendment 782 to the United States Sentencing Guidelines. Consistent with United States v. Helm , 891 F.3d 740 (8th Cir. 2018), we conclude that the district court impermissibly reduced Heaton's sentence below his amended guideline range, so we reverse and remand for resentencing.

Heaton pleaded guilty in 2012 to a conspiracy to participate in racketeering activity, and the district court sentenced him to 115 months' imprisonment. The court arrived at the…