Freeman v. United States
In brief
The Supreme Court overturned the Sixth Circuit and said some people with fixed-sentence plea deals may still qualify for shorter terms when the relevant federal sentencing range falls.
- Where it stands
- Decided
Decided 5-4 · June 23, 2011 · Opinion by Justice Kennedy
- What it’s about
- William Freeman sought a shorter prison term after the Sentencing Commission lowered the crack-cocaine Guidelines, even though his plea agreement specified his sentence.
- Who it affects
- Defendants whose plea agreements make a specific sentence a condition of pleading guilty may qualify for a reduction if the relevant sentencing range is later lowered; the ruling does not guarantee a reduction.
Summary: written with AI from the case record.
What it's about
The Supreme Court overturned the Sixth Circuit’s ruling and sent the case back to the lower court (remanded); four justices said people with such agreements may qualify for a reduction, and Justice Sotomayor agreed Freeman was eligible but for a different reason.
Federal law allows judges to reduce some prison sentences when the Sentencing Commission later lowers the relevant sentencing range.
Question presented
Does a federal judge have the authority to reduce a criminal sentence after the U.S. Sentencing Commission amends the Sentencing Guidelines if the judge has already accepted a plea agreement?
What the Court decided
Holding
The judgment is reversed, and the case is remanded. 355 Fed. Appx. 1, reversed and remanded. JUSTICE KENNEDY, joined by JUSTICE GINSBURG, JUSTICE BREYER, and JUSTICE KAGAN, concluded that defendants who enter into 11(c)(1)(C) agreements that specify a particular sentence as a condition of the guilty plea may be eligible for relief under §3582(c)(2).
- Result
- Reversed
The Court's reasoning
Justice Kennedy’s four-justice opinion said defendants whose plea agreements set a specific sentence as a condition of pleading guilty may qualify for a reduction when the relevant federal sentencing range is lowered. The Court did not order Freeman’s prison term reduced.
The vote
- Joined the judgment
- Concurred in a separate opinion
- Dissented
- Wrote an opinion
- Majority · 4joined the Court's opinion
- Breyer
- Kagan
- Kennedywrote the opinion
- Ginsburg
- Concurring · 1agreed with the result, wrote separately
- Sotomayorwrote separately
From the opinions
“I agree with the concurrence that the sentence imposed under a Rule 11(c)(1)(C) plea agreement is based on the agreement, not the Sentencing Guidelines.”
What's next
The case returns to the Sixth Circuit for further proceedings under the Supreme Court’s decision.
Documents
Opinions
Audio
Docket activity
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AI analysis generated: Case Briefing
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AI analysis generated: Impact Analysis
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AI analysis generated: Decision Record
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Audio Recording added: Oral Arguments - Freeman
Opinion added: Freeman
More questions
- What was Justice Sotomayor’s different view?
- She said a defendant may qualify if the plea agreement expressly uses the relevant Sentencing Guidelines range to set the sentence.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.