Minimal Explanatory Requirement for Within-Guidelines Sentences in § 3582(c)(2) Resentencing

Introduction

United States v. Eagle, 10th Cir. No. 24-7040 (Apr. 30, 2025), addresses the scope of a district court’s duty to explain its decision when reimposing a within-Guidelines sentence on a motion under 18 U.S.C. § 3582(c)(2). Scott Eagle, convicted of manslaughter in Indian country and felon-in-possession of a firearm, moved for a reduced sentence after the Sentencing Commission’s Amendment 821 lowered his advisory Guidelines range. The district court reduced his advisory range from 100–125 months to 87–108 months but chose to reimpose the original 100-month term using an AO-247 form with three paragraphs of reasoning. Eagle appealed, arguing the court’s explanation was procedurally deficient.

Key issues:

• What level of explanation must a district court provide when reimposing a within-Guidelines sentence on a § 3582(c)(2) motion?
• Is a short AO-247 form with minimal discussion sufficient in a “conceptually simple” resentencing?

Summary of the Judgment

The Tenth Circuit, speaking through Judge Carson, affirmed. It held that in “conceptually simple” cases, a district court need not give an elaborate explanation for reimposing a within-Guidelines sentence on a § 3582(c)(2) motion. Citing 18 U.S.C. §§ 3553(c)(1) and 3582(c)(2), and United States v. Chavez-Meza, 585 U.S. 109 (2018), the court reiterated that a brief AO-247 form order suffices when the record shows the judge considered the § 3553(a) factors and the parties’ arguments. Because the district court properly noted it had considered the amended range, the violent nature of the offense, and the § 3553(a) objectives, the explanation met the statutory threshold and was within the court’s discretion.

Analysis

1. Precedents Cited

• 18 U.S.C. § 3553(c)(1) – Requires a district court to “state the reason for imposing a sentence at a particular point within the range” when the sentence is within the Guidelines.
• 18 U.S.C. § 3582(c)(2) – Permits sentence reductions after a Guidelines amendment, “if such a reduction is consistent with applicable policy statements.”
• United States v. Chavez-Meza, 585 U.S. 109 (2018) – Holds that in “conceptually simple” cases, minimal explanation for a within-Guidelines sentence is adequate if the record shows consideration of the evidence and arguments.
• Rita v. United States, 551 U.S. 338 (2007) – Affirms that within-Guidelines sentences carry a presumption of reasonableness and need only concise explanations when the court considers the parties’ arguments.
• United States v. Verdin-Garcia, 824 F.3d 1218 (10th Cir. 2016), aff’d, 585 U.S. 109 (2018) – Confirms that explanatory duties at resentencing are no greater than at initial sentencing.
• United States v. Ruiz-Terrazas, 477 F.3d 1196 (10th Cir. 2007) – Holds that § 3553(c) does not require a “specific explanation” for within-Guidelines sentences.

2. Legal Reasoning

The court applied an abuse-of-discretion standard. Under § 3582(c)(2), the district court must consider the § 3553(a) factors and the Sentencing Commission’s policy statements, but it retains full discretion to decide whether to reduce a sentence. When the reimposed sentence remains within the amended Guidelines range, § 3553(c)(1)’s requirement to state reasons applies at a baseline level: the court must provide enough explanation to demonstrate that it considered the parties’ arguments and the statutory factors.

Here, the AO-247 order:

• Acknowledged the amended range (87–108 months) and that Eagle met criteria for reduction;
• Justified retention of the 100-month term based on the violent nature of the offense;
• Referenced explicit consideration of the § 3553(a) objectives—seriousness, deterrence, public protection, and proportionality.

The court found those three paragraphs sufficient under Chavez-Meza and its Tenth Circuit progeny, because they showed a reasoned basis and engagement with the evidence.

3. Impact

United States v. Eagle cements the Tenth Circuit’s minimal-explanation approach to § 3582(c)(2) resentencings:

• Resentencing hearings remain streamlined when the defendant receives a within-Guidelines sentence.
• District courts may rely on the AO-247 form and brief narrative to satisfy § 3553(c)(1), so long as the record shows meaningful consideration of the § 3553(a) factors.
• The decision reinforces the presumption that within-Guidelines sentences are reasonable and reduces appellate challenges aimed solely at explanatory sufficiency.

Future defendants seeking reductions under retroactive Guideline amendments should expect that short, focused explanations will usually suffice, especially in “conceptually simple” cases.

Complex Concepts Simplified

§ 3582(c)(2) Motion: A request to reduce a previously imposed prison term when the Sentencing Commission later lowers the applicable range.
AO-247 Form: A two-page administrative order allowing courts to check boxes and add minimal narrative when denying or modifying a sentence under § 3582(c)(2).
“Conceptually Simple” Case: One where the facts and legal questions at resentencing are straightforward, so only a concise explanation is necessary.
§ 3553(a) Factors: The statutory objectives for sentencing—seriousness, deterrence, protection of the public, rehabilitation, and consistency with similar cases.

Conclusion

United States v. Eagle reaffirms that district courts retain broad discretion in § 3582(c)(2) resentencings and need not labor over detailed explanations when reimposing within-Guidelines terms. By endorsing the use of a succinct AO-247 form order in “conceptually simple” cases, the Tenth Circuit preserves judicial efficiency while ensuring that the § 3553(a) factors remain integral to sentencing decisions. This decision underscores the enduring presumption of reasonableness for within-Guidelines sentences and clarifies the explanatory threshold for future sentence-reduction motions.