United States v. Lara: District Court Discretion to Deny Amendment 821 “Zero‑Point Offender” Reductions on § 3553(a) Grounds Alone

I. Introduction

The Eleventh Circuit’s unpublished decision in United States v. Reinaldo Marrero Lara, No. 24‑11639 (11th Cir. Nov. 25, 2025) (per curiam), addresses how district courts may respond to motions seeking sentence reductions under the U.S. Sentencing Commission’s 2023 “zero‑point offender” amendment (Amendment 821, now U.S.S.G. § 4C1.1).

Lara, a first‑time offender with no criminal history points, participated in a carefully planned kidnapping-for-ransom of a U.S. citizen in Mexico. After receiving a within‑Guidelines sentence of 192 months, he later applied for a sentence reduction under 18 U.S.C. § 3582(c)(2), arguing that he qualified as a zero‑point offender entitled to a retroactive two‑level reduction under § 4C1.1 and that the 18 U.S.C. § 3553(a) factors favored relief.

The district court denied relief on two independent grounds:

Lara was ineligible under § 4C1.1 because he aided and abetted a “crime of violence”, and
Even if he were eligible, the § 3553(a) factors weighed decisively against any reduction.

On appeal, the Eleventh Circuit affirmed solely on the second ground, holding that the district court did not abuse its discretion in concluding that the nature and seriousness of the offense, the need for deterrence, and the need to protect the public justified denying a reduction. The panel therefore expressly declined to decide whether Lara was actually eligible for the zero‑point offender decrease.

Although the opinion is “NOT FOR PUBLICATION” and thus non‑precedential in the Eleventh Circuit, it is an important early illustration of how appellate courts will review denials of Amendment 821 relief—and, in particular, how much discretion district judges retain to deny reductions even when a defendant appears to qualify as a zero‑point offender.

II. Factual and Procedural Background

A. The Offense Conduct

Between December 2013 and March 2014, Lara and his co‑conspirators traveled from the United States to Mexico in order to carry out a kidnapping for ransom targeting a U.S. citizen in Tulum, Mexico. The opinion’s facts (drawn from Lara’s factual proffer in connection with his guilty plea) show that:

Lara helped plan the kidnapping and traveled internationally to facilitate it.
He rented hotel accommodations and the vehicles used in the offense.
During the actual abduction in a parking garage in Tulum, Lara acted as a lookout while others:
- followed the victim into a parking garage,
- physically seized him,
- dragged him into a van,
- bound his hands and feet, and
- placed a hood over his head.
The victim was transported to a house, confined there, and a ransom was demanded from his father.
Days later, Lara helped retrieve the ransom from the drop location and participated in dividing the proceeds among the conspirators.

The sentencing judge characterized Lara’s conduct as “absolutely reprehensible” and a “horrible thing,” emphasizing the severe nature of the crime.

B. Charges, Plea, and Original Sentencing

In March 2015, Lara was indicted in the Southern District of Florida on three counts:

Conspiracy to kidnap a person in a foreign country, in violation of 18 U.S.C. §§ 956(a)(1), 1201(a)(1) (Count 1);
Conspiracy to commit kidnapping, in violation of 18 U.S.C. § 1201(a)(1), (c) (Count 2); and
Kidnapping, in violation of 18 U.S.C. §§ 1201(a)(1), (2) (Count 3).

Pursuant to a plea agreement, Lara pleaded guilty to Count 2 (conspiracy to commit kidnapping). The remaining counts were dismissed.

The Presentence Investigation Report (PSI) calculated:

Base offense level: 32 under U.S.S.G. § 2A4.1(a) (kidnapping),
Specific offense characteristic: +6 under § 2A4.1(b)(1) because the victim was kidnapped for ransom,
Acceptance of responsibility: –3 under § 3E1.1(a), (b).

This yielded a total offense level of 35.

On the criminal history side, the PSI assigned Lara a criminal history score of 0, meaning:

he had no prior conviction for which a sentence of at least 60 days had been imposed under U.S.S.G. § 4A1.1, and
he fell into Criminal History Category I.

With total offense level 35 and Category I, the advisory Guidelines range was 168–210 months. The district court imposed:

Imprisonment: 192 months (middle of the range), and
Supervised release: five years.

The sentencing judge explicitly cited the seriousness of the offense and the need for deterrence as justifying a within‑Guidelines sentence.

C. Amendment 821 and the Zero‑Point Offender Guideline (§ 4C1.1)

On November 1, 2023, the Sentencing Commission’s Amendment 821 took effect. One key component (now codified at U.S.S.G. § 4C1.1) creates a new two‑level reduction in the offense level for certain “zero‑point offenders” — defendants with no criminal history points under Chapter 4.

Under § 4C1.1(a), a defendant may receive this decrease only if he meets a list of ten criteria, including (as relevant here):

(1) he did not receive any criminal history points; and
(3) he did not use violence or credible threats of violence in connection with the offense.

Amendment 821 was made retroactive, meaning qualifying inmates serving sentences may seek reductions under 18 U.S.C. § 3582(c)(2) where the amended Guideline would have lowered their advisory range.

D. Lara’s § 3582(c)(2) Motion and the District Court’s Ruling

Proceeding pro se, Lara filed a motion under 18 U.S.C. § 3582(c)(2), arguing:

He was eligible as a “zero‑point offender” under § 4C1.1 because he had zero criminal history points and met the other criteria; and
The § 3553(a) factors, coupled with his favorable post‑sentencing conduct, warranted a two‑level reduction.

The government opposed the motion. The district court denied it, issuing an order that:

Eligibility holding: Found Lara ineligible under § 4C1.1(a)(3) because he had “aided and abetted a crime of violence.”
§ 3553(a) holding: Independently held that a reduction was “inappropriate” based on:
- the nature and seriousness of the offense (including extensive planning, international travel, and stalking of the victim and his family),
- the need for deterrence, and
- the need to protect the public from further crimes.

Lara appealed these two rulings, claiming both that he was eligible under § 4C1.1 and that the district court misapplied the § 3553(a) factors.

III. Summary of the Eleventh Circuit’s Opinion

The Eleventh Circuit affirmed the denial of Lara’s § 3582(c)(2) motion. Critically, the court:

Did not decide whether Lara was actually eligible for the zero‑point offender reduction under § 4C1.1; and
Affirmed solely on the district court’s application of the § 3553(a) sentencing factors.

Applying an abuse‑of‑discretion standard (citing United States v. Webb, 565 F.3d 789 (11th Cir. 2009)), the panel held:

The district court’s explanation of its § 3553(a) analysis was sufficient under Eleventh Circuit law (citing United States v. Cook, 998 F.3d 1180 (11th Cir. 2021)).
The court acted within its discretion in placing decisive weight on:
- the nature and circumstances of the offense,
- the seriousness of the offense,
- the need for deterrence, and
- the need to protect the public.
It was not an abuse of discretion for the district court:
- to give less weight to Lara’s claimed post‑conviction rehabilitation (United States v. Tinker, 14 F.4th 1234 (11th Cir. 2021)), or
- to give little weight to alleged sentencing disparities with co‑defendants (United States v. Cavallo, 790 F.3d 1202 (11th Cir. 2015); United States v. Cabezas‑Montano, 949 F.3d 567 (11th Cir. 2020)).

The panel relied on Sapuppo v. Allstate Floridian Ins. Co., 739 F.3d 678 (11th Cir. 2014), to explain that because the district court rested its ruling on two independent grounds, the appellant had to show error as to both. By affirming on the § 3553(a) ground alone, the court avoided resolving the precise scope of eligibility under § 4C1.1(a)(3).

In short, the Eleventh Circuit held that, even assuming arguendo Lara might be eligible for a zero‑point offender reduction, the district court did not abuse its discretion in denying a reduction based on the § 3553(a) factors.

IV. Analysis

A. Statutory and Guideline Framework

1. Sentence modification under 18 U.S.C. § 3582(c)(2)

Section 3582(c)(2) permits—but does not require—courts to reduce previously imposed sentences when:

The defendant “has been sentenced to a term of imprisonment based on a sentencing range that has subsequently been lowered by the Sentencing Commission,” and
The reduction is consistent with applicable policy statements issued by the Sentencing Commission.

Even when these conditions are met, the statute says the court “may” reduce the term, “after considering the factors set forth in section 3553(a).” Thus, eligibility under a retroactive amendment (like § 4C1.1) is necessary but not sufficient; the district court retains broad discretion to deny a reduction after re‑weighing the § 3553(a) factors.

The panel echoes earlier Eleventh Circuit precedent in describing § 3582(c)(2) as a “limited and narrow” exception to the general rule that a sentence is final (United States v. Armstrong, 347 F.3d 905, 909 (11th Cir. 2003)).

2. The § 3553(a) factors

The opinion recites the full list of § 3553(a) factors, but focuses in particular on the first four:

Nature and circumstances of the offense and the defendant’s history and characteristics;
Need for the sentence to:
- reflect the seriousness of the offense,
- promote respect for the law, and
- provide just punishment;
Need for deterrence (both specific and general); and
Need to protect the public from further crimes of the defendant.

The panel stresses that district courts have substantial latitude in how they weigh these considerations. Citing United States v. Rosales‑Bruno, 789 F.3d 1249 (11th Cir. 2015), and United States v. Butler, 39 F.4th 1349 (11th Cir. 2022), the opinion reiterates:

The weight assigned to each factor is “committed to the sound discretion of the district court.”
Courts are not required to give “equal weight” to all factors.
Appellate review does not “second guess” that weighting so long as the resulting sentence (or, here, decision on a reduction) is reasonable in light of the record.

3. The new zero‑point offender guideline (§ 4C1.1)

While the Eleventh Circuit declines to resolve the eligibility question under § 4C1.1, the opinion underscores an important structural point: § 4C1.1 only affects the offense level; it does not override § 3553(a). The new guideline does not entitle anyone to a reduction; it merely:

provides a mechanism by which certain first‑time, non‑violent offenders can receive a lower advisory Guidelines range, and
creates a basis for a § 3582(c)(2) motion if the original sentence was “based on” a range that Amendment 821 subsequently lowered.

Lara’s case illustrates that, even for defendants with zero criminal history points, district courts remain fully empowered to deny reductions when:

the underlying conduct was serious and violent,
the planning and execution were sophisticated or prolonged, or
the risk to the public was substantial.

B. Precedents Cited and Their Influence

The court weaves several Eleventh Circuit precedents into its relatively compact analysis. They serve two roles: (1) defining the standard of review and the latitude afforded to district courts, and (2) setting limits on particular arguments, such as reliance on co‑defendant sentence disparities.

1. Sapuppo v. Allstate Floridian Ins. Co., 739 F.3d 678 (11th Cir. 2014)

Sapuppo articulated a key appellate principle: when a district court’s judgment is based on multiple, independent grounds, an appellant must show that each ground is incorrect to obtain reversal. If any one ground is valid, the judgment stands.

The court invokes Sapuppo in a footnote to explain why it need not address Lara’s eligibility under § 4C1.1. Because the district court denied relief on two distinct bases:

ineligibility under § 4C1.1, and
§ 3553(a) factors weigh against reduction,

the appellate panel can affirm solely by upholding the § 3553(a) analysis. This is a common technique in appellate practice, especially where one issue (here, the proper interpretation of § 4C1.1(a)(3) in violent‑offense contexts) may be sensitive or unsettled.

2. United States v. Webb, 565 F.3d 789 (11th Cir. 2009)

Webb establishes that the standard of review for denials of § 3582(c)(2) motions is abuse of discretion. This standard is highly deferential:

The appellate court asks whether the district court’s decision fell within a range of reasonable choices.
Mere disagreement with the district judge’s weighing of factors is insufficient.

3. United States v. Armstrong, 347 F.3d 905 (11th Cir. 2003)

Armstrong underscores that § 3582(c)(2) provides only a “limited and narrow” exception to the finality of criminal sentences. By citing this case, the panel situates Lara’s motion as an exception to the rule of finality, not as a quasi‑resentencing. That perspective colors the court’s willingness to defer to the district judge’s assessment of the § 3553(a) factors.

4. United States v. Rosales‑Bruno, 789 F.3d 1249 (11th Cir. 2015) and United States v. Butler, 39 F.4th 1349 (11th Cir. 2022)

These decisions define the degree of discretion district courts enjoy when weighing § 3553(a) factors:

Rosales‑Bruno confirms that the weight assigned to each factor is for the district court to decide.
Butler reiterates that appellate courts will not “second guess” that weighing absent unreasonableness.

In Lara, these cases support the proposition that the district court was entitled to give:

heavy weight to offense seriousness, deterrence, and public protection; and
little or no weight to mitigating factors like rehabilitation or co‑defendant disparities.

5. United States v. Cook, 998 F.3d 1180 (11th Cir. 2021)

Cook deals with the sufficiency of a sentencing court’s explanation. It holds that a court must give enough reasoning about § 3553(a) so that “meaningful appellate review” is possible, but it does not need to address every argument or provide a lengthy discussion.

The Lara panel cites Cook to hold that the district court satisfied this requirement by:

reciting relevant offense facts (planning, international travel, stalking of the victim and family, violent nature of the kidnapping, ransom collection), and
linking those facts explicitly to the § 3553(a) goals of seriousness, deterrence, and public protection.

In effect, Cook protects district courts from having their § 3582(c)(2) decisions overturned merely because their written explanation is brief, as long as the reasoning is clear and anchored in the statutory factors.

6. United States v. Tinker, 14 F.4th 1234 (11th Cir. 2021)

Tinker stands for two propositions relevant here:

A district court’s § 3553(a) analysis need not systematically discuss every piece of mitigating evidence.
It is within the court’s discretion to assign relatively little weight to rehabilitation or other mitigators if other factors dominate.

Lara relied in part on “favorable post‑sentencing conduct.” The panel emphasizes that the district court’s failure to mention this expressly did not amount to error. Under Tinker, it is enough that the court considered the statutory factors; it is not obliged to catalog every pro‑defendant detail.

7. United States v. Irey, 612 F.3d 1160 (11th Cir. 2010) (en banc)

Irey provides a detailed articulation of the abuse‑of‑discretion standard in sentencing. It explains that reversal is warranted only when the appellate court has a “definite and firm conviction” that the district court committed a “clear error of judgment” in weighing the § 3553(a) factors.

The Lara panel quotes this standard to emphasize how high the bar is for overturning a district court’s sentencing‑related judgment. Given Lara’s extensive involvement in a violent kidnapping conspiracy, it was unlikely that the Eleventh Circuit would conclude that a continued 192‑month sentence lay outside the “range of reasonable sentences dictated by the facts.”

8. United States v. Cavallo, 790 F.3d 1202 (11th Cir. 2015) and United States v. Cabezas‑Montano, 949 F.3d 567 (11th Cir. 2020)

These two cases concern sentencing disparities among co‑defendants. As a general rule:

Cavallo holds that “[d]isparity between the sentences imposed on codefendants is generally not an appropriate basis for relief on appeal.”
Cabezas‑Montano approves a higher sentence for the captain of a drug‑smuggling vessel because his role made him “more culpable” than other crew members.

Lara argued that it was unfair that two of his co‑defendants received § 4C1.1 reductions while he did not. The Eleventh Circuit dismissed this claim, reasoning that:

those co‑defendants had “materially more limited” roles in the conspiracy, and
greater culpability justifies a harsher sentence even among co‑participants in the same crime.

This underscores a crucial point: § 3553(a)(6) — the need to avoid unwarranted disparities among similarly situated defendants — focuses on national sentencing consistency, not fine‑tuned alignment among co‑defendants with different roles.

C. The Court’s Legal Reasoning in Lara

1. Deeming the explanation sufficient under § 3553(a)

The panel first evaluates whether the district court provided enough reasoning for its denial. Applying Cook, it concludes that the order:

clearly indicated that the court had “considered the § 3553(a) factors,” and
backed up its conclusion with a factual narrative focused on the offense’s seriousness and Lara’s significant role.

The district court specifically highlighted:

Planning and preparation: months of planning, coordination, and international travel;
Targeting and surveillance: stalking the victim and his family;
Violence and coercion: the abduction, binding, hooding, confinement, and ransom demands;
Financial motive: Lara’s participation in retrieving and splitting the ransom.

These facts were then expressly tied to:

the seriousness of the crime and the need for just punishment (§ 3553(a)(2)(A)),
the need for deterrence (§ 3553(a)(2)(B)), and
the need to protect the public (§ 3553(a)(2)(C)).

Given that level of explanation, the Eleventh Circuit found that “meaningful appellate review” was possible, satisfying the requirements of Cook.

2. Discretionary weighting of the § 3553(a) factors

Having found the explanation adequate, the panel then assesses whether the district court’s weighing of the factors was an abuse of discretion. Relying on Rosales‑Bruno, Butler, Tinker, and Irey, it holds that:

The district court was entitled to give significant weight to the offense’s seriousness and Lara’s central role.
The court was not required to give equal (or any particular) weight to other factors such as:
- post‑sentencing rehabilitation, or
- co‑defendant sentencing disparities.
Nothing about the resulting decision — maintaining a 192‑month sentence for a key participant in a violent kidnapping-for-ransom — fell outside the range of reasonable outcomes.

Notably, the Eleventh Circuit quotes Lara’s own characterization of his conduct as “reprehensible,” using his admission to bolster the conclusion that the denial of a reduction was not a clear error of judgment.

3. Treatment of co‑defendant disparities

Lara’s disparity argument failed for two interrelated reasons:

Codefendants had lesser roles. The court notes that the co‑defendants who obtained § 4C1.1 reductions “had a materially more limited role in the conspiracy.” That difference in culpability fully justifies different outcomes under § 3553(a)(6) and existing Eleventh Circuit precedent.
Codefendant disparities are usually not a basis for relief. Citing Cavallo, the panel reiterates that sentencing differences among co‑defendants “generally” do not warrant relief. The primary concern of § 3553(a)(6) is avoiding unjustified national disparities, not mechanically equalizing outcomes among co‑participants.

This underscores that, in the Eleventh Circuit, defendants will face an uphill battle when arguing that co‑defendant outcomes alone require a reduction or reversal.

4. Strategic avoidance of the eligibility issue under § 4C1.1

Finally, the panel relies on Sapuppo to decline to reach the eligibility question under § 4C1.1(a)(3). The district court had reasoned that Lara was ineligible because he aided and abetted a “crime of violence,” which it took to be inconsistent with the requirement that the defendant not have used violence or threats of violence in connection with the offense.

By affirming on § 3553(a) grounds alone, the Eleventh Circuit:

left undecided the precise contours of § 4C1.1(a)(3), including:
- whether a conspirator or accomplice in a violent crime can ever satisfy the “no violence or credible threats of violence” requirement, and
- how to treat roles such as lookout, driver, or planner in that analysis; and
nonetheless signaled that, even if some zero‑point violent‑offense defendants might technically qualify as eligible, district courts retain broad authority to deny reductions on § 3553(a) grounds.

D. Impact and Likely Future Significance

1. For district courts: wide discretion to deny Amendment 821 reductions

Lara offers district judges in the Eleventh Circuit a fairly clear roadmap for denying Amendment 821 motions:

They may assume without deciding that the defendant is eligible under § 4C1.1 and proceed directly to the § 3553(a) analysis.
They may deny relief based exclusively on the § 3553(a) factors as long as they:
- explicitly reference those factors, and
- tie that analysis to record‑supported facts (e.g., planning, violence, victim impact, role).
A succinct explanation that emphasizes the seriousness of the offense, need for deterrence, and protection of the public will typically withstand appellate scrutiny.

This is particularly significant in violent or sophisticated offenses where the defendant has no prior criminal history but the underlying conduct is grave. Judges can:

recognize that the Commission has created a new path to relief for certain zero‑point offenders, yet
reasonably determine that specific defendants, like Lara, do not merit a reduction because of the offens e’s characteristics.

2. For defendants and defense counsel: eligibility is only the starting point

For defendants seeking Amendment 821 relief, Lara is a cautionary example:

Proving eligibility (zero criminal history points and satisfaction of § 4C1.1’s criteria) does not compel a reduction.
The central battleground will often be the § 3553(a) factors:
- Defendants must present a compelling narrative showing that their offense, read in full context, does not warrant continued incarceration at the current level.
- They must also emphasize rehabilitation, lack of risk to the public, and any changed circumstances—but should be aware that the court is not required to give those arguments significant weight.
Arguments based on co‑defendant disparities will rarely carry the day unless the co‑defendants truly are similarly situated in role and culpability (which was not the case for Lara).

3. For prosecutors: a template for opposing zero‑point motions in serious cases

Prosecutors can read Lara as validation of a common opposition strategy:

Concede or even assume eligibility under § 4C1.1, but
argue vigorously that:
- the nature and scope of the offense,
- any violence or threats involved,
- the planning and sophistication of the criminal conduct, and
- ongoing needs for deterrence and public safety
justify denying any reduction under § 3553(a).

Lara shows that such arguments, where well supported by the record, will likely be sustained on appeal.

4. For the development of Amendment 821 jurisprudence

Because the Eleventh Circuit expressly declined to reach the eligibility issue, Lara does not settle key interpretive questions about § 4C1.1(a)(3). Future, published decisions in the circuit (or other circuits) will need to address:

Whether defendants involved in violent offenses, but who themselves did not personally commit physical violence (e.g., lookouts, planners, drivers), may still qualify as having not “used violence or credible threats of violence”; and
How to treat conspiracy or aiding‑and‑abetting liability in assessing this criterion.

Nevertheless, Lara contributes an early example of the practical boundary around Amendment 821 relief: whatever the precise contours of eligibility, district courts will retain broad authority to deny reductions in serious violent cases based on § 3553(a).

V. Complex Concepts Simplified

1. What is a § 3582(c)(2) sentence reduction?

A § 3582(c)(2) motion is not a full resentencing or a new trial. Instead, it is a narrow mechanism that allows a judge to:

look back at the original sentence,
determine whether the Sentencing Commission has since lowered the applicable Guidelines range, and
decide whether to reduce the sentence in light of that change and the § 3553(a) factors.

The key points:

The judge is not required to reduce the sentence, even if the range is lower.
The judge ordinarily cannot revisit everything about the original conviction or Guidelines calculations; the focus is on the effect of the new amendment.

2. What is a “zero‑point offender” under § 4C1.1?

A “zero‑point offender” is a defendant who:

has no criminal history points under Chapter 4 of the Guidelines (i.e., typically no prior convictions significant enough to score points), and
meets a list of additional criteria designed to identify genuinely low‑risk, non‑violent, first‑time offenders.

Such offenders may qualify for a two‑level reduction in offense level, which can lower the advisory sentencing range. But this does not:

guarantee any particular sentence, nor
override the judge’s duty to consider § 3553(a).

3. “Crime of violence,” aiding and abetting, and conspiracy

In federal sentencing, a “crime of violence” generally refers to an offense involving the use, attempted use, or threatened use of physical force (or certain listed offenses). Kidnapping is a classic example.

Aiding and abetting means helping or facilitating someone else’s crime, with intent to make it succeed.
Conspiracy is an agreement between two or more individuals to commit a crime, often coupled with an overt act in furtherance of that agreement.

Crucially, even if a conspirator does not personally wield a weapon or physically harm the victim, the law may treat him as responsible for reasonably foreseeable acts of co‑conspirators in furtherance of the conspiracy. That issue lurks in the background of the district court’s eligibility analysis (though the Eleventh Circuit does not resolve it).

4. Abuse of discretion

The “abuse of discretion” standard is highly deferential to the district court:

An appellate court will not overturn a decision just because it might have decided differently.
Instead, it asks whether the decision lies within a broad “range of reasonable choices” given the facts and the law.
Reversal requires a “definite and firm conviction” that the court made a clear error of judgment in weighing the relevant factors.

In practice, this means that as long as the district court:

correctly understands the law,
considers the appropriate factors (like § 3553(a)), and
explains its decision in a way that fits the record,

its ruling on a § 3582(c)(2) motion is very likely to be upheld.

5. Sentencing disparities among co‑defendants

Although § 3553(a)(6) instructs courts to avoid “unwarranted sentence disparities,” it does not mean that co‑defendants must receive identical or even similar sentences. The key ideas are:

Sentences may properly differ when defendants have different roles, levels of culpability, or criminal histories.
The primary concern is avoiding unjustified differences across the country for similar offenders and offenses—not harmonizing every case involving co‑defendants.

Lara’s greater involvement in planning and executing the kidnapping justified his harsher sentence compared to co‑defendants with “materially more limited” roles.

VI. Conclusion

United States v. Lara, though unpublished, provides a clear and instructive example of how the Eleventh Circuit views sentence‑reduction motions under § 3582(c)(2) after Amendment 821:

It confirms that eligibility for a zero‑point offender reduction under § 4C1.1 does not compel a sentence reduction.
It emphasizes that district courts retain broad discretion to deny such motions based solely on a reasonable application of the § 3553(a) factors.
It reinforces the principle that the seriousness of the offense, the need for deterrence, and the need to protect the public can, standing alone, justify maintaining the original sentence, even for a first‑time offender with no prior criminal history.
It underscores that co‑defendant disparities rarely provide a successful basis for relief where roles and culpability differ.

Going forward, Lara will likely be cited (at least persuasively) as authority for the proposition that district courts may, and often will, deny Amendment 821 sentence‑reduction motions in serious violent cases, even where defendants appear to satisfy the zero‑point criteria. Its central message is that the newly created zero‑point offender adjustment operates within, not above, the familiar § 3553(a) framework—and that framework leaves substantial room for judicial judgment and caution in violent conspiracies like Lara’s kidnapping‑for‑ransom scheme.