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 improperly assessed for prior convictions that should instead have been treated as relevant conduct under U.S.S.G. § 1B1.3.
According to Hastings, the alleged error increased her criminal-history category and unlawfully hindered her eligibility for relief under Amendment 821. The Northern District of Texas 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 incorrectly calculated—is a challenge to the legality or duration of her sentence.
Such a challenge belongs in a direct appeal or a motion under 28 U.S.C. § 2255, not a sentence-modification motion under § 3582(c). The court therefore concluded that Hastings could not use § 3582(c) to pursue her Guidelines-calculation challenge.
Key Takeaways
- A claim that criminal-history points were incorrectly assessed challenges the calculation and legality of the sentence.
- Section 3582(c) cannot be used as a substitute for a direct appeal or a § 2255 motion.
- The Fifth Circuit affirmed the denial without reaching the merits of Hastings’s relevant-conduct argument.
Why It Matters
The decision reinforces the limited scope of § 3582(c) proceedings. Defendants generally cannot use a sentence-modification motion to relitigate alleged errors in the original Guidelines calculation, even when those alleged errors may affect eligibility for relief under a later Guidelines amendment.