U.S. v. Koglin

Dist. Ct. did not err in denying defendant’s motion to reduce his sentence under 18 USC section 3582(c)(2) based on retroactive 2014 amendment to drug-quantity sentencing guideline. Record showed that retroactive sentencing guideline required that defendant’s offense level be reduced from 32 to 30, and defendant failed to show that his “bottom-line, final [sentencing] range” would have been lower had retroactive sentencing guideline been in existence at time of his original sentence, since: (1) Dist. Ct. had similarly reduced his offense level at original sentencing hearing from 32 to 30 under section 2D1.1(a)(5) of USSG; and (2) reduction under 2D1-1(a)(5) would not have been available to defendant under retroactive guideline.