United States v. Jorge Alberto Navarro

In this appeal, we examine the scope of the United States Sentencing Commission’s (the “Commission”) authority to limit the retroactive effect of its amendments to its Sentencing Guidelines. We hold that a district court cannot apply a retroactive amendment to reduce an already imposed sentence prior to that amendment’s effective date. We also hold that the Commission’s determination of the appropriate effective date for a retroactive amendment is not invalid simply because the Commission made reference to prisoners’ rehabilitative needs. We therefore affirm.

I.

A.

In 2008, Jorge Avila Alberto Navarro pled guilty to possession with intent to distribute methamphetamine. At sentencing, the district court calculated the appropriate Guidelines range to be 151 to 188 months. On the government’s motion, the district court imposed a below-Guidelines sentence of 113 months imprisonment. Under that sentence, Navarro is scheduled to be released on September 9, 2015.

On November 1, 2014, the Commission issued Amendment 782 to its Sentencing Guidelines, which lowered the recommended sentences for certain drug crimes, including the crime of which Navarro was convicted. See United…