Judge Christopher Droney
Christie sold guns and participated in 2002 and 2003 conspiracies to distribute crack cocaine. He pleaded guilty in 2003. His Category V criminal history and adjusted offense level of 31 yielded a Sentencing Guidelines range of 168 to 201 months. In 2004 district court sentenced him to 168 months’ in prison and 60 months’ supervision. It granted him sentence reduction in light of the 2007 Sentencing Guidelines amendments lowering penalties for crack cocaine offenses. However, on Jan. 4, 2013, the court denied his Jan. 30, 2012, motion under 18 USC §3582(c)(2) to further reduce sentence in light of similar amendments in 2011. Second Circuit vacated and remanded the denial as inadequately explained despite Christie’s eligibility for such reduction. Discussing United States v. Cavera and distinguishing United States v. Fernandez, the circuit concluded that district court’s lack of reasoning prevented exercise of “meaningful appellate review.” Discussing rulings from the Eighth, Seventh, Sixth and Eleventh circuits, the circuit concluded that its determination that at least some minimal statement of reasons for a court’s action on a §3582(c)(2) motion is required was in accord with the view of every other circuit addressing the issue.
