DISCLAIMER: The following unofficial case summaries are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
173314P.pdf 03/20/2019 United States v. Stirling Michael Heaton
U.S. Court of Appeals Case No: 17-3314
U.S. District Court for the District of Minnesota - St. Paul
[PUBLISHED] [Colloton, Author, with Wollman and Benton, Circuit Judges]
Criminal case - Sentencing. In granting a sentencing reduction under
Amendment 782, the district court erred under the policy statement in
Guidelines Sec. 1B1.10(b)(2)(A) in reducing defendant's sentence below the
minimum amended guideline range; constitutional challenge to Sec. 1B1.10
rejected as it was not irrational for the Commission to avoid undue
complexity and litigation by adopting a uniform limitation on reductions
tied to the amended guidelines range; reversed and remanded for entry of
sentence not less than the applicable 110-month minimum of the amended
guidelines range.