18 U.S.C. \u00a7 3553(a)(1)<\/a>, a sentence reduction may be in order if the district court fails to consider the defendant’s history and characteristics, which came into play in the case described below.<\/p>\nIf the appellate court determines that a sentence reduction is warranted, it will issue a mandate to the district court that must be followed. The Second Circuit case of Burrell v. U.S.<\/em> confirmed this principle, which is known as the mandate rule.<\/p>\nThe Sentence Reduction Issue in U.S. v. Sawyer<\/em><\/h2>\nIn the case of U.S. v. Sawyer<\/em>, the defendant received a 30-year prison sentence after pleading guilty to several counts of sexual offenses involving children. Before the defendant’s most recent appeal, the Second Circuit already remanded the case back to the district court once before because the appellate court determined that the sentencing judge did not sufficiently take into account the defendant’s troubled upbringing in imposing a sentence. There was a substantial amount of evidence in the record that the defendant had endured a horrific childhood. The defendant also did not have any significant criminal history prior to this case.<\/p>\nThe district court granted a sentence reduction to the defendant to 25 years in prison, but the district court judge did not do so for the reasons cited by the appellate court. Instead of finding the original sentence incorrect based on the defendant’s characteristics and history, the district court cited the defendant’s rehabilitative efforts since he had been sentenced as the reason why his sentence was reduced by five years. The district court went so far as to note its disagreement with the Second Circuit’s ruling that its original sentence was unreasonable in light of the serious nature of the crime. The defendant promptly appealed the reduced sentence based on reasonableness grounds as well as the fact that the district court openly disagreed with the appellate court’s conclusion.<\/p>\n
The appellate court eventually ruled that it is irrelevant whether the sentencing judge adopted the same reasoning the appellate court laid out in its ruling so long as the actual mandate from the appellate court is effectively implemented. Here, the district court reduced the defendant’s sentence by a substantial amount, and the fact that the sentencing judge did so for different reasons than the appellate court cited is of no consequence.<\/p>\n