Koons v. United States

Koons v. United States
Supreme Court of the United States
Decided June 4, 2018
Full case name	Koons v. United States
Docket no.	17-5716
Citations	584 U.S. ___ ( more )
Holding
A person who has been sentenced based on a mandatory minimum sentence with a statutory justification for a longer sentence, rather a justification within the Guidelines, is not entitled to sentence reductions under subsequent amendments to the Guidelines.
Court membership
Chief Justice John Roberts Associate Justices Anthony Kennedy  · Clarence Thomas Ruth Bader Ginsburg  · Stephen Breyer Samuel Alito  · Sonia Sotomayor Elena Kagan  · Neil Gorsuch
Case opinion
Majority	Alito, joined by unanimous

Koons v. United States, 584 U.S. ___(2018), was a United States Supreme Court case in which the court held that a person who has been sentenced based on a mandatory minimum sentence with a statutory justification for a longer sentence, rather a justification within the Guidelines, is not entitled to sentence reductions under subsequent amendments to the Guidelines. ^{[1] [2]}

Background

The five petitioners in this case pleaded guilty to drug conspiracy charges that subjected them to mandatory minimum sentences. Before imposing their sentences, the federal district court calculated their advisory Guidelines ranges. However, because the top end of the Guidelines ranges fell below the mandatory minimums, the court concluded that the mandatory minimums superseded the Guidelines ranges. After discarding these ranges, the court departed downward from the mandatory minimums to reflect the convicted people's substantial assistance to the government in prosecuting other drug offenders. In settling on the final sentences, the court considered the relevant "substantial assistance factors" set out in the Guidelines, but it did not consider the original Guidelines ranges that it had earlier discarded. ^[1]

After these people were sentenced, the Sentencing Commission amended the Guidelines and reduced the base offense levels for certain drug offenses, including those for which petitioners were convicted. The petitioners sought sentence reductions under a law that makes defendants eligible for a sentence reduction if they were sentenced "based on a sentencing range" that was later lowered by the Sentencing Commission. The courts below held that petitioners were not eligible because they could not show that their sentences were "based on" the now-lowered Guidelines ranges. ^[1]

Opinion of the court

The Supreme Court issued an opinion on June 4, 2018. ^[1]

References

1. Koons v. United States,No. 17-5716 , 584 U.S. ___(2018).
2. Berman, Douglas (June 4, 2018). "Opinion analysis: Justices discard game effort to extend eligibility for sentence reduction". SCOTUSblog. Retrieved August 4, 2025.

External links

• Text of Koons v. United States,No. 17-5716, 584 U.S. ___(2018) is available from: Justia

This article incorporates written opinion of a United States federal court. As a work of the U.S. federal government, the text is in the public domain .