United States v. John Brown, Jr.

Appellant John Brown, Jr., appeals the district court’s sua sponte order denying the sentence reduction that would have accompanied retroactive application of an amendment to the Sentencing Guidelines. We affirm.

I. BACKGROUND

After a trial, a jury convicted Brown of (1) conspiracy to possess cocaine with intent to distribute and conspiracy to distribute cocaine (Count 1) and (2) possession of a firearm during a drug trafficking offense (Count 3). The district court sentenced Brown to 405 months’ imprisonment on Count 1, followed by a 60-month consecutive sentence on Count 3. This Court…