Unreported / Non-Citable
Background
Federal prisoner Amberly Hastings filed a pro se motion under 18 U.S.C. §§ 3582(c)(1)(B) and 3582(c)(2). She argued that three criminal-history points were incorrectly assessed for prior convictions that should instead have been classified as relevant conduct under U.S.S.G. § 1B1.3.
According to Hastings, the alleged error increased her criminal-history category and improperly hindered her eligibility for relief under Amendment 821. The district court denied the motion, and Hastings renewed her sentencing challenges on appeal.
The Court’s Holding
The Fifth Circuit affirmed. It held that Hastings’s claim—that her Guidelines range was calculated incorrectly—challenged the legality or duration of her confinement.
Such a challenge must be pursued through a direct appeal or a motion under 28 U.S.C. § 2255, not through a sentence-modification motion under § 3582(c). The court therefore upheld the district court’s denial without reaching the merits of the asserted criminal-history error.
Key Takeaways
- A claimed error in calculating a defendant’s Guidelines range cannot be litigated through a § 3582(c) motion.
- Challenges to the legality or duration of a federal sentence belong on direct appeal or in a § 2255 proceeding.
- The Fifth Circuit affirmed without deciding whether Hastings’s prior convictions should have been treated as relevant conduct.
Why It Matters
The decision reinforces the limited role of § 3582(c): it is a sentence-modification mechanism, not a vehicle for collateral attacks on the original sentencing calculation. Defendants seeking to correct an allegedly unlawful Guidelines calculation must use the procedurally appropriate avenue.