Frazier: One page order suffices to deny 3582(b) relief

In U.S. v. Frazier, No. 15-14640 (May 24, 2016), the Court affirmed the denial of a motion for a sentence reduction under 18 U.S.C. § 3582(c)(2). In a one-page order, the district court stated that although Frazier was eligible for a reduced sentence under Guideline Amendment 782, which amended the drug quantity guidelines, “his career offender status, post-sentence conduct in prison, additional state court conviction for murder, and his leadership role in a large-scale drug-trafficking organization counsel against this Court exercising its discretion to reduce Frazier’s sentence.” The Court held that “such an analysis is all that is required to survive our level of scrutiny . . . so long as the record demonstrates that the pertinent factors were taken into account by the district court.” The district court did not abuse its discretion by failing to address explicitly the effect of the Fair Sentencing Act of 2010, or Frazier’s positive efforts to improve his character.