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Hughes v. U.S. and Koons v. U.S. (Decisions June 4, 2018)

Supreme Court clarifies when a criminal defendant may qualify for a sentence reduction.

Defendants in each of these cases sought clarification on a particular law. The criminal code provides for eligibility defendants to get sentence reductions in certain cases. It depends on how the defendant’s original sentence was calculated.

If the defendants’ original sentence was “based on” the Sentencing Guidelines and then the Sentencing Guidelines for that offense are reduced, then the defendant is eligible.

The defendants in Hughes and Koons each ended up with sentences below the Sentencing Guidelines ranges for their offenses, but it’s possible their sentences were nevertheless “based on” the Guidelines. That’s what the Court was asked to clarify here.

Sentencing Guidelines vs. Mandatory Minimums

There are a couple of guidelines that a judge considers in ordering a criminal sentence. The Mandatory Minimum/Maximum is a range designated by Congress that the sentence must comply with. Only in certain rare cases can a defendant get out of that range. And then there’s the “Sentencing Guidelines,” a range that the judge may use with discretion, as long as the Mandatory Min/Max are respected.

Hughes and Koons

Hughes and the Koons defendants were all sentenced with unusual circumstances.

Hughes took a plea deal. So the sentencing judge was deciding whether to approve the suggestion offered in the plea deal. The judge first calculated the Sentencing Guidelines and then approved the suggestion, which was lower than the Sentencing Guidelines.

The five Koons defendants had helped the prosecution out, so they qualified to get sentences lower than the Mandatory Minimums. For the Koons sentences, the sentencing judge calculated both the Sentencing Guidelines and the Mandatory Minimums. But then the judge decided to take a percentage of the Mandatory Minimums as a way to determine the defendants’ reduced sentences.

Different turnouts

The Supreme Court interpreted – for these unusual circumstances – when a reduced sentence can qualify for a sentence reduction. That is, when is a reduced sentence “based on” the Sentencing Guidelines.

The answer is in the infographic. See how the Court’s interpretation resulted in different turnouts for each case.

Here is the Hughes opinion. And here is Koons.

Earlier reports

Our earlier reports on the cases give more information about the cases. Check them out here: Hughes and Koons.

Hughes v. U.S. and Koons v. U.S. (Decisions June 4, 2018)

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About the Author

Mariam Morshedi

Mariam Morshedi

Mariam Morshedi is the Founder and Executive Director of Subscript Law. Before starting Subscript Law, she practiced civil rights law for AARP Foundation, where she litigated housing, consumer and disability rights issues.

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