Koons v. United States
Issues
Can defendants subject to a mandatory minimum sentence, but who received a sentence below that minimum for substantially assisting the government, receive a further sentence reduction under 18 U.S.C. § 3582 when the Sentencing Commission retroactively lowers the sentencing guidelines range that would have applied absent the mandatory minimum?
Koons and his co-petitioners were convicted of federal drug charges but received sentences below the statutory minimum because they “substantially assist[ed]” the government. The United States Sentencing Commission subsequently retroactively reduced the sentencing guidelines ranges for the crimes for which they were sentenced. Koons sought a further sentence reduction under 18 U.S.C. § 3582(c)(2), which provides for a sentence reduction when the initial sentencing was based on a sentencing range that had been subsequently lowered by the Sentencing Commission. Koons argues he is eligible for the sentence reduction because the Sentencing Guidelines were initially consulted in determining his sentencing range. The United States counters that he is ineligible for the sentence reduction because his sentence was ultimately based on the statutorily prescribed minimum sentence. The decision in this case has implications for sentencing disparities, the influence of mandatory minimums, and the power of the Sentencing Commission.
Questions as Framed for the Court by the Parties
Whether a defendant who is subject to a statutory mandatory minimum sentence, but who substantially assisted the government and received a sentence below the mandatory minimum pursuant to 18 U.S.C. § 3553(e), is eligible for a further sentence reduction under 18 U.S.C. § 3582(c)(2), when the Sentencing Commission retroactively lowers the advisory sentencing guidelines range that would have applied in the absence of the statutory mandatory minimum.
This case is a consolidated appeal from five petitioners—Timothy Koons, Kenneth Jay Putensen, Randy Feauto, Esequiel Gutierrez, and Josea Gadea—who have all been previously convicted of methamphetamine conspiracy offenses. United States v. Koons, 850 F.3d 973, 975 (8th Cir. 2017). In November 2012, defendant Randy Feauto pleaded guilty to conspiracy to manufacture and distribute methamphetamine and unlawful possession of a firearm. Id.
Edited by
Additional Resources
- Brandon Sample, Certiorari Granted By Supreme Court In Three New Criminal Appeals, Sentencing.net (Dec. 10, 2017).
- Koons v. United States, Ballotpedia.