Freeman v. United States

2011-06-23

Headline: Court allows many federal defendants who accepted binding plea deals to seek reduced sentences when their guideline range is later lowered, reversing an appeals court’s categorical bar and reopening relief claims.

Holding: The Court reversed the Sixth Circuit and held that defendants who entered plea agreements recommending a specific sentence can seek sentence reductions under § 3582(c)(2) when the judge relied on a Guidelines range later reduced, subject to judicial discretion.

Real World Impact:

Permits some defendants with binding plea deals to seek sentence reductions after guideline changes.
Requires judges to assess whether a sentence was based on the Guidelines.
Does not guarantee reductions; judges retain discretion and can deny relief.

Topics: federal sentencing, plea deals, sentencing guidelines, sentence reductions

Summary

Background

William Freeman, a federal defendant, pleaded guilty under a Rule 11(c)(1)(C) plea agreement in which the parties recommended a specific 106-month sentence and stated they had reviewed the Sentencing Guidelines. The District Court accepted the agreement, calculated the Guidelines range the parties expected, and imposed the recommended 106 months. Later, the Sentencing Commission retroactively lowered the Guidelines range applicable to Freeman, and he moved under 18 U.S.C. § 3582(c)(2) for a sentence reduction; the District Court and the Sixth Circuit denied relief, prompting review here.

Reasoning

The central question was whether a sentence imposed after a binding plea agreement can be considered “based on” a Guidelines range for purposes of § 3582(c)(2). A plurality of Justices concluded that a categorical bar to relief for 11(c)(1)(C) plea agreements is unsupported. The plurality explained that judges must exercise independent sentencing discretion, consult the Guidelines when appropriate, and may grant reductions when the original sentence was based on a range later lowered. Justice Sotomayor concurred in the judgment but drew a narrower rule: a (C) plea sentence is ordinarily based on the agreement itself, yet relief is available when the agreement expressly uses a Guidelines range. The dissent would generally bar relief for (C) agreement sentences.

Real world impact

The decision lets defendants who entered binding plea deals ask judges to revisit sentences tied to Guidelines ranges later reduced by the Sentencing Commission. It does not automatically shorten sentences: district judges retain discretion, and policy limits and appellate review constrain reductions.