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Drug sentence reductions

Koons v. United States

Updated Oct 18, 2026

In brief

The defendants lost their bid for another sentence cut, and the Supreme Court left the Eighth Circuit's ruling in place.

Where it stands
Decided

Decided 9-0 · June 4, 2018 · Opinion by Justice Alito

What it’s about
Timothy Koons and four other drug defendants sought further sentence cuts after sentencing guidelines were lowered; their sentences had already been reduced below required minimums because they helped the government.
Who it affects
The ruling leaves Koons and the four other defendants unable to get another cut based on Amendment 782.

Summary: written with AI from the case record.

Illustration for Koons v. United States
Conceptual illustration · AI-generated

What it's about

The Supreme Court unanimously agreed with the Eighth Circuit that they could not get another reduction because their sentences were based on the required minimums and their assistance, not the guideline ranges.

Their original guideline ranges were below the minimum sentences required by law. After they helped the government, a judge reduced their sentences below those minimums.

Amendment 782 lowered guideline levels for most drug quantities, prompting the defendants to seek another sentence reduction.

Question presented

1. Whether the Eighth Circuit Court of Appeals erred in holding, contrary to the opinion of the Fourth Circuit Court of Appeals, that defendants whose initial advisory guideline sentencing range was below a statutory mandatory minimum and who were subsequently sentenced below that minimum after the district court granted a government motion for reduction in sentence for substantial assistance pursuant to 18 U.S.C. § 3553(e), are not eligible for further reduction in sentence under 18 U.S.C. § 3582(c)(2) and retroactive sentencing guideline Amendment 782, which lowered the base offense levels assigned to most drug quantities? 2. Whether Freeman v. United States , 564 U.S. 522 (2011) (plurality opinion) supports the holding that there is a substantive limitation on the term "based on" in 18 U.S.C. § 3582(c)(2) that prohibits defendants whose initial advisory guideline range was below a statutory mandatory minimum, and who were subsequently sentenced below that minimum after the district court granted a government motion for reduction in sentence for substantial assistance pursuant to 18 U.S.C. § 3553(e), from being eligible for further reduction in sentence due to retroactive sentencing guideline Amendment 782?

What the Court decided

Holding

Adjudged to be AFFIRMED. Alito, J., delivered the opinion for a unanimous Court.

Result
Affirmed

The vote

  • Joined the judgment
  • Wrote an opinion
Majority · 9joined the Court's opinion
  1. Breyer
  2. Kagan
  3. Thomas
  4. Kennedy
  5. Ginsburg
  6. Sotomayor
  7. Roberts
  8. Gorsuch
  9. Alitowrote the opinion
9 justices joined the judgment.

What's next

The Supreme Court has finished the case, and the Eighth Circuit's ruling remains in place for these defendants.

Documents

2

Docket activity

7
  • New analysis added

    Oct 18, 2026 · Court records

  • AI analysis generated: Case Briefing

    Oct 18, 2026 · Generated

  • AI analysis generated: Decision Record

    Oct 18, 2026 · Generated

  • Case data updated: summary, question_presented, generation_metadata

    Oct 18, 2026 · Court records

  • Case data updated: question_presented, extraction_metadata

    Oct 18, 2026 · Court records

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  • Opinion added: opinion

    Jun 4, 2018 · Court records

  • Brief added: Questions Presented

    Court records

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.

Checked Oct 18, 2026Methodology

Court records and filings

Reporting and analysis