Modifications of Sentences (Part 2)

The Court continued: Because the record as a whole demonstrates the judge had a reasoned basis for his decision, the judge’s explanation for petitioner’s sentence reduction was adequate. The Government argues petitioner was not entitled to an explanation at all because the statute governing sentence-modification motions does not expressly require a sentencing judge to state his reasons for imposing a particular sentence. See §3582(c)(2).

It is unnecessary to go as far as the Government urges, however, because, even assuming the District Court had a duty to explain its reasons when modifying petitioner’s sentence, what the court did here was sufficient. Petitioner contends that a district court must explain its reasoning in greater detail when the court imposes a “disproportionate” sentence reduction—that is, when the court reduces the prisoner’s sentence to a different point in the amended Guidelines range than the court previously selected in the original Guidelines range. That argument is unconvincing.

As a technical matter, determining “proportionality” may prove difficult when the sentence is somewhere in the middle of the range. More importantly, the choice among points on the Guidelines range often reflects the belief that the chosen sentence is the “right” sentence based on various factors, including those found in §3553(a). If the applicable Guidelines range is later reduced, it is unsurprising that the sentencing judge may choose a nonproportional point in the new range.

Even assuming that a judge reducing a prisoner’s sentence must satisfy the same explanation requirement that applies at an original sentencing, the District Court’s explanation was adequate. At the original sentencing, petitioner asked for a downward variance from the Guidelines range, which the judge denied. The judge observed that petitioner’s sentence was high because of the destructiveness of methamphetamine and the quantity involved.

It would be natural for the Petitioner to infer that the judge gave a disproportional downgrade because s/he did not agree with the Legislature’s decision to amend the sentencing range for methamphetamine distribution. Since the majority did not require a further explanation from the judge, we will never know his or her true reasoning.