United States v. Estacio: Eleventh Circuit Reaffirms Broad District-Court Discretion to Deny § 3582(c)(2) Reductions After Amendment 821

Introduction

In United States v. Henri Manrique Estacio, No. 24-12702 (11th Cir. May 9, 2025) (unpublished), the Eleventh Circuit confronted one of the first appellate challenges dealing with retroactive Sentencing Guideline Amendment 821. Although Amendment 821’s newly minted § 4C1.1 (“zero-point offender” adjustment) generally reduces eligible defendants’ offense levels by two, the district court refused to trim Estacio’s 70-month sentence. The question on appeal was not eligibility—everyone agreed Estacio qualified—but whether the district court had abused its discretion in declining to reduce the sentence after recalculating a lower guideline range.

By affirming, the Eleventh Circuit underscored a decisive principle: eligibility does not equal entitlement. District courts retain wide latitude under 18 U.S.C. § 3582(c)(2) to deny sentence reductions when the § 3553(a) factors—particularly the seriousness of the offense—outweigh the mitigating effect of a new, lower guideline range.

Summary of the Judgment

Eligibility Acknowledged: Estacio’s zero criminal history points and other characteristics meant that Amendment 821 decreased his total offense level from 27 to 25, dropping his advisory range from 70–87 months to 57–71 months.
District Court’s Decision: Despite the new range, the court denied relief, stressing (1) the vast quantity of cocaine actually involved (only 10% was seized) and (2) the need for the sentence to reflect the offense’s gravity.
Appellate Holding: Applying abuse-of-discretion review, the Eleventh Circuit affirmed. The panel ruled that the lower court properly:
- Recalculated the guidelines under Step 1, and
- Exercised its discretionary Step 2 judgment grounded in the § 3553(a) factors.
Key Takeaway: Amendment 821 is retroactive, but relief remains discretionary—district courts can, and sometimes should, withhold reductions where the original sentence already represents a significant break or the § 3553(a) calculus points the other way.

Analysis

A. Precedents Cited

The panel leaned heavily on established Eleventh Circuit caselaw, most notably:

United States v. Williams, 557 F.3d 1254 (11th Cir. 2009) – Clarifies the two-step process for § 3582(c)(2) motions and limits retroactivity to amendments listed in § 1B1.10(d).
United States v. Bravo, 203 F.3d 778 (11th Cir. 2000) – Originated the “two-step” framework (recalculate, then reassess via § 3553(a)).
United States v. Butler, 39 F.4th 1349 (11th Cir. 2022) – Affirms that district courts may attach “great weight” to any single § 3553(a) factor.
United States v. Doyle, 857 F.3d 1115 (11th Cir. 2017) – Holds post-sentencing rehabilitation is discretionary, not mandatory, in § 3582(c)(2) determinations.

Together, these cases establish that (i) the Commission can authorize retroactivity, but (ii) courts are never compelled to grant a reduction, and (iii) appellate review is deferential.

B. Legal Reasoning

Step 1—Guideline Recalculation:
- Amendment 821 + Amendment 825 made § 4C1.1 retroactively applicable as of 1 February 2024.
- Estacio met each statutory and guideline criterion for the two-level “zero-point offender” decrease.
- Recalculated range: 57–71 months.
Step 2—§ 3553(a) Re-Assessment:
- Nature & seriousness. The district court stressed the “massive” maritime cocaine operation; although only 30 kg were seized, circumstantial evidence suggested up to 300 kg on board.
- Unwarranted disparities. Because Estacio already benefited from the government’s inability to retrieve 90% of the drugs, further leniency would create disparity compared with similarly situated traffickers.
- Public safety & deterrence. Large-scale drug smuggling through international waters implicates significant public-safety and deterrence interests—concerns the court found paramount.
Deference on Appeal. Citing Giron and others, the Eleventh Circuit reiterated that an abuse occurs only when a decision is arbitrary, premised on wrong law, or unsupported by the record—none applied here.

C. Likely Impact of the Decision

1. Practical Guidance for Practitioners. Defense counsel should temper client expectations: even when Amendment 821 applies, a persuasive, individualized showing under the § 3553(a) factors remains essential.

2. Judicial Discretion Reaffirmed. The opinion arms district judges with precedential ammunition to deny reductions when they believe the original sentence already under-represents culpability—particularly in drug-quantity disputes or cases with uncharged conduct.

3. Future Litigation. Expect divergent district-court outcomes; appellate review will be highly deferential. The real battleground will be fact-based arguments about seriousness, deterrence, and rehabilitation rather than strict eligibility.

Complex Concepts Simplified

18 U.S.C. § 3582(c)(2): A statute letting courts lower a prison sentence if the Sentencing Commission later reduces the guideline range used at the original sentencing—but only if the Commission makes the change retroactive.
Amendment 821 (§ 4C1.1): Added a two-level reduction for “zero-point” offenders—people with no criminal history points and meeting nine other safety criteria (no violence, no sex offenses, etc.).
Two-Step § 3582 Process:
1. Recalculate the range with the new amendment.
2. Resentence (or not) after weighing § 3553(a) factors.
Courts can stop at Step 2 if they decide a lower sentence is not justified.
§ 3553(a) Factors: Ten statutory considerations guiding sentencing, such as seriousness of the offense, deterrence, public protection, and alignment with guideline policy statements.
“Low-Profile Vessel” (LPV): A semisubmersible craft designed to ride low in the water, reducing radar and visual detection—commonly used in oceanic drug smuggling.
“Safety Valve” (§ 5C1.2): A guideline allowing certain non-violent, low-level drug defendants to bypass mandatory-minimum sentences if they meet five criteria.

Conclusion

United States v. Estacio drives home a fundamental post-Amendment 821 reality: while the Sentencing Commission has opened the door to shorter sentences for zero-point offenders, district courts still hold the key. The Eleventh Circuit’s unpublished yet instructive opinion confirms that appellate courts will rarely disturb a district court’s discretionary refusal to grant a § 3582(c)(2) reduction—especially where the record supports a finding that the existing sentence already errs on the side of leniency. For lawyers and judges alike, the case is a lodestar illustrating how to balance retroactive guideline amendments against the enduring weight of the § 3553(a) factors.