Freeman v. United States — Roberts, J., dissenting

Summary

Justice Roberts dissents, arguing that a sentence imposed under a Rule 11(c)(1)(C) plea agreement is grounded solely in the agreement itself and therefore should not be considered “based on” a Sentencing Guidelines range for purposes of 18 U.S.C. § 3582(c)(2). He contends that the majority’s test allowing reduction when the agreement references the Guidelines is arbitrary and unworkable. The dissent maintains that only the explicit terms of the plea dictate eligibility for sentence reduction. (Roberts, dissenting.)