UNITED STATES v. JONES (2025)

ORDER DENYING MOTIONS FOR SENTENCE REDUCTION

In 2022, Christopher Jamal Jones pled guilty to one count of conspiring to possess and distribute five hundred or more grams of methamphetamine. On January 9, 2023, the Court sentenced Mr. Jones to 108 months in prison. Mr. Jones has filed two motions to reduce his sentence. His first Motion, filed on May 9, 2025, seeks to reduce his sentence pursuant to 18 U.S.C. § 3582(c)(2), because the United States Sentencing Commission (“Commission”) has published proposed amendments to the United States Sentencing Guidelines (“Guidelines”) that could reduce sentencing disparities. Motion to Reduce Sentence (“3582(c)(2) Motion”), [ECF No. 124]. His second Motion, filed on July 18, 2025, seeks to reduce his sentence pursuant to 18 U.S.C. § 3582(c)(1), contends that the sentencing disparity between his sentence and similarly situated defendants is disproportionately high, and that this disparity presents “any other circumstance” that the Court would find “extraordinary and compelling.” Motion to Reduce Sentence (“3582(c)(1) Motion”), [ECF No. 126] (first citing U.S.S.G. § 1B1.13(b)(5); then citing 18 U.S.C. § 3582(c)(1)).

A proposed amendment to the Guidelines cannot give rise to a sentence reduction under 18 U.S.C. § 3582(c)(2). And a sentencing disparity, standing alone, is not a circumstance that is “similar in gravity” to other reasons that the Court could grant a sentence reduction pursuant to the Guidelines. Accordingly, the Motions are DENIED.

BACKGROUND

On October 1, 2021, a grand jury returned an indictment charging Mr. Jones and a co-defendant with: (I) conspiracy to possess with intent to distribute five hundred (500) grams or more of a mixture and substance containing a detectable amount of methamphetamine, see 21 U.S.C. § 846(b)(1)(A)(viii); and (II) attempting to possess with intent to distribute five hundred (500) grams or more of a mixture and substance containing a detectable amount of methamphetamine, see 21 U.S.C. § 841(a)(1). [ECF No. 12].

Mr. Jones knowingly and voluntarily entered into a plea agreement as to Count I of the indictment on August 29, 2022. [ECF No. 45]. The Court held a sentencing hearing on January 9, 2023. [ECF No. 71]. At the hearing, the Court sentenced Mr. Jones to 108 months’ imprisonment for Count I, at the low end of the advisory guideline range as modified by the First Step Act of 2018. [ECF No. 72]; Sentencing Hearing Tr., [ECF No. 104] at 29:11–16.

Mr. Jones filed a motion to vacate his sentence pursuant to 18 U.S.C. § 2255 on January 22, 2024, [ECF No. 119]. The Court denied the motion and closed the case on March 5, 2024. [ECF No. 123].

The 3582(c)(2) Motion was filed on May 9, 2025, [ECF No. 124], and the Government responded on May 15, 2025. Gov't’s Resp. in Opp'n to 3582(c)(2) Motion, [ECF No. 125]. The 3582(c)(1) Motion was filed on July 18, 2025, and the Government responded on July 29, 2025. Gov't’s Resp. in Opp'n to 3582(c)(1) Motion, [ECF No. 127]. Both Motions are ripe for review.

LEGAL STANDARD

Generally, “[a] ‘court may not modify a term of imprisonment once it has been imposed except’ in certain circumstances established by statute or rule.” United States v. Handlon, 97 F.4th 829, 831 (11th Cir. 2024) (quoting 18 U.S.C. § 3582(c)). Mr. Jones invokes two provisions of 18 U.S.C. § 3582(c) to support his case.

Under § 3582(c)(1)(A), a district court may consider a defendant's motion for a sentence reduction if he “has fully exhausted” his administrative remedies.¹ 18 U.S.C. § 3582(c)(1)(A). After this procedural bar has been met, a defendant must bear the burden of showing that he is eligible for a sentence reduction. United States v. Green, 764 F.3d 1352, 1356 (11th Cir. 2014). Thus, the defendant must show the Court that he qualifies under either one or a combination of the six factors enumerated in § 1B1.13. Even if one or some combination of the extraordinary and compelling reasons listed above is present, the Court must still determine that early release remains consistent with “the factors set forth in § 3553(a) to the extent that they are applicable” before a sentence reduction is proper. See 18 U.S.C. § 3582(c)(1)(A). These factors include “the nature and circumstances of the offense, the history and characteristics of the defendant, the seriousness of the crime, the promotion of respect for the law, just punishment, protecting the public from the defendant's further crimes, and adequate deterrence.” United States v. Prada, No. 22-13059, 2024 WL 1298461, at *1 (11th Cir. Mar. 27, 2024) (citing 18 U.S.C. § 3553(a)).

The § 3553(a) inquiry is separate from § 3582(c)(1)(A). See Dillon v. United States, 560 U.S. 817, 826–27, 130 S.Ct. 2683, 177 L.Ed.2d 271 (2010) (noting that a court must first determine whether a sentence reduction is consistent with the Commission's policy statements before evaluating whether the reduction is warranted under § 3553(a)). While analyzing eligibility under § 3582(c)(1)(A) requires that courts assess whether a defendant qualifies under the terms of the sentence-reduction statute, § 3553(a) allows courts to determine in their discretion whether “the authorized reduction is warranted, either in whole or in part, according to the factors set forth in § 3553(a).” United States v. Bryant, 996 F.3d 1243, 1251 (11th Cir. 2021) (quoting Dillon, 560 U.S. at 826–27, 130 S.Ct. 2683); see also id. (referring to the § 3582(c)(1)(A) analysis as a question of statutory interpretation that is reviewed de novo on appeal, and the § 3553(a) analysis as a discretionary one reviewed for abuse of discretion).

Thus, under § 3582(c)(1)(A), the district court may reduce a movant's term of imprisonment if: (1) there are “extraordinary and compelling reasons” for doing so, (2) the factors listed in § 3553(a) favor doing so, and (3) doing so is consistent with the policy statements in § 1B1.13. United States v. Tinker, 14 F.4th 1234, 1237 (11th Cir. 2021). If the district court finds against the movant on any one of these requirements, it cannot grant relief and need not analyze the other requirements. United States v. Giron, 15 F.4th 1343, 1347–48 (11th Cir. 2021); Tinker, 14 F.4th at 1237–38 (explaining that “nothing on the face of 18 U.S.C. § 3582(c)(1)(A) requires a court to conduct the compassionate-release analysis in any particular order”).

The inquiry under 18 U.S.C. § 3582(c)(2) is distinct. “[I]n the case of a defendant who has been sentenced to a term of imprisonment based on a sentencing range that has subsequently been lowered by the Sentencing Commission pursuant to 28 U.S.C. § 994(o),” a court may reduce the term of imprisonment, after considering the factors set forth in section 3553(a) to the extent that they are applicable, if such a reduction is consistent with applicable policy statements issued by the Sentencing Commission.” 18 U.S.C. § 3582(c)(2).

ANALYSIS

Mr. Jones's 3582(c)(2) Motion is premature. Mr. Jones relies on a proposed amendment to Section 2D1.1 of the Guidelines. But that proposed amendment has not yet taken effect, and the Court lacks authority to reduce any prisoner's sentence pursuant to it. E.g., U.S. v. McCarthy, No. 09-395, 2014 WL 4211306, at *2 (M.D. Fla. Aug. 26, 2014); see also, e.g., U.S. v. Peak, 579 F. App'x 888, 891 (11th Cir. 2014) (noting that “the district court is required to use the Guidelines Manual in effect on the date of sentencing”) (citing United States v. Bailey, 123 F.3d 1381, 1403 (11th Cir. 1997)). Because Mr. Jones's sentence has not “subsequently been lowered by the Sentencing Commission pursuant to 28 U.S.C. § 994(o),” 18 U.S.C. § 3582(c)(2) cannot apply, and the 3582(c)(2) Motion must be denied without prejudice.

Mr. Jones's 3582(c)(1) Motion cannot stand, because he does not qualify for relief under that section. To qualify, a defendant must “present[ ] any other circumstance or combination of circumstances that, when considered by themselves or together with any of the reasons described in paragraphs (1) through (4), are similar in gravity to those described in paragraphs (1) through (4).” § 1B1.13(b)(5). The subsection allows courts to reduce a defendant's sentence if—for example—the defendant presents a “terminal illness,” like “metastatic solid-tumor cancer, “is suffering from a medical condition that requires long-term or specialized medical care that is not being provided and without which the defendant is at risk of serious deterioration in health or death,” or “is at increased risk of suffering severe medical complications as a result of exposure to [an] ongoing outbreak of infectious disease.” § 1B1.13(b)(1). Alternatively, the defendant's age may warrant a sentence reduction, if the defendant “is at least 65 years old,” “is experiencing a serious deterioration in physical or mental health because of the aging process,” and “has served at least 10 years or 75 percent of his or her term of imprisonment, whichever is less.” § 1B1.13(b)(2). Family circumstances may also warrant a sentence reduction due to the “death or incapacitation” of a close family member. § 1B1.13(b)(3). Finally, a defendant may be eligible for a sentence reduction if they were the victim of sexual abuse involving a sexual act or physical abuse resulting in serious bodily injury that was committed by any individual who had custody or control of the defendant while he was serving his term of imprisonment. § 1B1.13(b)(4).

Defendant's 3582(c)(1) Motion states that the sentence disparity between him and similarly situated defendants renders him eligible for a sentence reduction. 3582(c)(1) Motion at 2–3. But the mere fact that a “sentencing enhancement tied to drug purity has come under judicial scrutiny” does not qualify as a reason “similar in gravity” to other provisions in the Guidelines. Judicial scrutiny is not similar in seriousness or circumstance to one's terminal medical condition, one's medical condition due to age, the wellbeing of a family member, or the fact that one was abused while in custody. Even if judicial skepticism over certain sentencing guidelines were an appropriate basis for granting a sentence reduction, Mr. Jones's citations in support would do him no favors. As Mr. Jones concedes, each of the cases he cites in support relate to downward variances granted at a defendant's initial sentencing, and do not deal with sentence reductions. Mot. at 2 (first citing United States v. Nawanna, 321 F. Supp. 3d 943, 950 (N.D. Iowa 2018) (expressing a policy disagreement with the methamphetamine guidelines at sentencing); then citing United States v. Johnson, 379 F. Supp. 3d 1213, 1229 (M.D. Ala. 2019) (discussing the ability for a district court to implement a downward variance based on policy disagreements with the methamphetamine guidelines at sentencing); and then citing United States v. Robinson, No. 21-14, ECF No. 103 at 5–6 (S. D. Miss. filed Dec. 23, 2022)). Because sentencing is separate and distinct from a sentence reduction, Mr. Jones's citations are inapposite and do not diminish this Court's conclusion that his 3582(c)(1) Motion also fails. See Handlon, 97 F.4th at 831 (noting that courts generally may not modify a term of imprisonment after it has been imposed).

CONCLUSION

Because Mr. Jones has failed to show that he is eligible for a sentence reduction under 18 U.S.C. § 3582(c)(1) or § 3582(c)(2), his Motions, [ECF Nos. 124, 126], are DENIED.

DONE AND ORDERED in Miami, Florida this 9th day of September, 2025.

FOOTNOTES

1.   Mr. Jones has exhausted his administrative remedies, and the Government does not contest this point. Section 3582(c)(1) Mot. at 2, 5.

RODOLFO A. RUIZ II, UNITED STATES DISTRICT JUDGE