United States v. Eric Smith

OPINION

Eric Smith, a pro se federal prisoner, appeals the district court’s denial of his motion to reduce his 360-month sentence pursuant to 18 U.S.C. § 3582(c)(2), which can permit a sentence reduction when a prisoner was sentenced based on a sentencing range that has subsequently been lowered. Smith’s sentence was based on the Sentencing Guidelines for drug-trafficking offenses, U.S.S.G. § 2D1.1, even though he also qualified as a career offender under U.S.S.G. § 4B1.1. Amendment 782 to § 2D1.1 subsequently lowered the drug-trafficking offense level applicable to Smith’s case, and that…