Hughes v. United States

Background

Erik Hughes pleaded guilty to drug and gun charges after agreeing with the Government to a binding plea deal that set his sentence at 180 months. At sentencing the judge calculated an advisory Guidelines range of 188 to 235 months, accepted the parties’ 180-month agreement, and imposed that sentence. Months later the Sentencing Commission made a Guidelines change retroactive, lowering Hughes’ range to 151 to 188 months. Hughes asked the district court to reduce his sentence; the court and the Eleventh Circuit denied relief.

Reasoning

The Court addressed whether people sentenced under a binding Rule 11(c)(1)(C) plea deal can seek a lower sentence if the advisory Guidelines range later drops. The majority said yes when the judge relied on the Guidelines range as part of the framework for accepting the deal or imposing the sentence. The opinion explains that the Guidelines remain the starting point for most federal sentences and that a sentence is “based on” a range if that range was a basis for the judge’s decision. A defendant is eligible for reconsideration unless the record shows the judge would have imposed the same sentence regardless of the lower range.

Real world impact

The decision makes some people who took binding plea deals eligible to ask for shorter federal terms when the Commission lowers a relevant Guidelines range. District judges keep discretion and must weigh sentencing factors and the original bargain before granting a reduction. This case was sent back to the lower court to decide whether Hughes’ sentence should be reduced.

Dissents or concurrances

Justice Sotomayor wrote a separate opinion that joined the judgment but explained her different earlier view; Chief Justice Roberts dissented, joined by Justices Thomas and Alito, arguing Type-C sentences are based on the plea deal itself, not the Guidelines.