United States v. Todd Bryant

SUTTON, Circuit Judge.

Todd Bryant was charged with conspiracy to distribute large quantities of cocaine and marijuana, and an undetermined amount of ecstasy. As part of a plea agreement, Bryant pleaded guilty only to the marijuana offense and accepted a 71-month sentence. Nearly two years after Bryant took the plea, Amendment 782 to the Sentencing Guidelines retroactively reduced the sentencing ranges for federal drug trafficking crimes. Bryant asked the district court to reduce his sentence under Amendment 782, and the district court obliged. But because Bryant explicitly waived the right to…