On June 4, 2018, the Supreme Court issued its decision in Hughes v. United States, which held, in a 6-3 Opinion by Justice Kennedy, that a defendant who pleads guilty in a negotiated plea can benefit from later changes in the sentencing guidelines if the district court relied on the guideline range in imposing the sentence or accepting the plea agreement. This is an important decision for the many federal criminal defendants who have entered into a “Type-C” plea agreements under Federal Rule of Criminal Procedure 11(c)(1)(C), for offenses with sentencing guidelines that are later reduced by the Sentencing Commission. Under a Type-C plea agreement, the defendant and the Government are permitted to agree to a specific sentence or range of sentence as the appropriate sentence for the case, which binds the court once it accepts the plea agreement. Hughes confirms that such a defendant may seek relief of a reduced sentenced under 18 U.S.C. § 3582(c)(2). However, a Type-C agreement, to be “based on” the defendant’s Guidelines range, must be part of the “framework the district court relied on in imposing the sentence or accepting the agreement.” Read the full decision here.
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