The defendant had initially received a 110-month federal sentence in Florida. He then received a 360-month federal sentence in North Carolina, which was to run consecutively. He completed his Florida sentence in 2009 and began serving the North Carolina sentence. In 2012, he filed motions to reduce his North Carolina sentence based on retroactive guideline amendments, and the federal court in North Carolina reduced his 360-month sentence to 235 months. In 2014, following Amendment 782, he filed a pro se motion seeking a reduction of his Florida sentence. The court denied the motion on the ground that the defendant had already completed that term of imprisonment. The district court subsequently denied his motion for reconsideration, and he appealed 14 days later.
As an initial matter, the Court found that the defendant's notice of appeal was timely. The government argued that the defendant's reconsideration motion was actually a motion to correct the sentence under Rule 35, and it therefore did not toll the time for appeal. The Court rejected that argument, concluding that the court's denial of the 3582(c)(2) motion did not impose a new sentence and thus did not implicate Rule 35. The defendant's appeal, filed within 14 days from the denial of the reconsideration motion, was therefore timely.
On the merits, however, the Court concluded that the defendant was ineligible for a sentencing reduction, because he had already completed his Florida term of imprisonment. The Court rejected the defendant's argument that his two federal sentences were aggregated, and he was therefore only serving a single federal sentence for purposes of 3582(c)(2). The Court rejected his reliance on: 18 U.S.C. 3584, which aggregates sentence for "administrative purposes" only; on habeas cases interpreting the "in custody" requirement; and on consecutive sentences imposed under 924(c) in a single proceeding. The Court emphasized that the defendant was sentenced in different courts, at different times, and for different drug offenses, and thus there was no reason to aggregate the sentences for 3582(c)(2) purposes. The Court expressly reserved whether sentences may be aggregated when a statutory mandatory consecutive sentence and a guidelines sentence are imposed in the same proceeding.