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No. 17-155October Term 2017Decided Jun 4, 2018

Docket 17-155October Term 2017 (2017–2018)

Hughes v. United States

Federal defendants with Rule 11(c)(1)(C) plea deals are usually not barred from seeking sentence cuts after retroactive Guidelines changes.

Case status

Current stage
Decided
Latest event
Decision released Jun 4, 2018
Case Accepted
Arguments
Decision ReleasedJun 4, 2018
What it's about

This case was about whether a federal defendant who accepted a plea deal for a specific sentence under Rule 11(c)(1)(C) can later ask for a reduced sentence when the Sentencing Commission lowers the applicable sentencing range. The Court held that the sentence is generally "based on" the Guidelines if the Guidelines range was part of the framework the judge used in accepting the plea or imposing the sentence.

Question presented

1. Whether this Court's decision in Marks means that the concurring opinion in a 4-1-4 decision represents the holding of the Court where neither the plurality's reasoning nor the concurrence's reasoning is a logical subset of the other. 2. Whether, under Marks, the lower courts are bound by the four-Justice plurality opinion in Freeman, or, instead, by Justice Sotomayor's separate concurring opinion with which all eight other Justices disagreed. 3. Whether, as the four-Justice plurality in Freeman concluded, a defendant who enters into a Fed. R. Crim. P. 11(c)(1)(C) plea agreement is generally eligible for a sentence reduction if there is a later, retroactive amendment to the relevant Sentencing Guidelines range.

Case path

United States Court of Appeals for the Eleventh Circuit / Decision released Jun 4, 2018

Area

Criminal Procedure

Briefing

What it's about

The case asked whether a federal defendant who agreed to a specific sentence in a Rule 11(c)(1)(C) plea deal can later seek a shorter sentence when the Sentencing Commission lowers the relevant Guidelines range. The Court said the answer is generally yes when the Guidelines range was part of the framework the judge used to accept the plea or impose the sentence.

Vote

The Court decided the case on June 4, 2018, after argument on March 27, 2018, but the prompt does not provide the vote count or opinion lineup.

Impact

This affects federal prisoners who took plea deals for set sentences and later may benefit from retroactive guideline changes. For example, a person sentenced under a plea deal could ask for a reduction if the sentencing range used by the judge is later lowered.

What's next

Lower courts must apply this rule when deciding sentence-reduction requests in similar federal plea cases. Defendants still must show that the Guidelines range was part of the judge's framework in their own sentencing.

What was the main fight in Hughes v. United States?

The dispute was whether a defendant with a plea deal for a specific sentence could later seek a reduction after a retroactive Guidelines change. It also raised confusion about how lower courts should read Freeman.

Who is most affected by this decision in real life?

Federal defendants who accepted Rule 11(c)(1)(C) plea deals are most affected. Some can now ask for shorter sentences when the sentencing range used in court is later lowered.

What happens after the Supreme Court's decision in this case?

Lower courts now use this rule in future sentence-reduction cases. Individual defendants still must show the Guidelines mattered in the judge's sentencing framework.

Decision

Decision record

What the Court decided

Federal defendants with Rule 11(c)(1)(C) plea deals are usually not barred from seeking sentence cuts after retroactive Guidelines changes.

Impact

This affects federal prisoners who took plea deals for set sentences and later may benefit from retroactive guideline changes. For example, a person sentenced under a plea deal could ask for a reduction if the sentencing range used by the judge is later lowered.

Not official Court text.

Opinion documents