## Facts

- Amanda Williams pled guilty in federal court to participating in a methamphetamine-distribution conspiracy, including conduct in a drug-free zone.
- A statute imposed a 120-month mandatory minimum sentence.
- Williams provided substantial assistance to authorities in investigating and prosecuting other offenders.
- The government moved for a departure under U.S.S.G. § 5K1.1 and for authority to sentence below the mandatory minimum under 18 U.S.C. § 3553(e).
- The district court reduced the sentence from 120 months to 78 months based on substantial assistance.
- The district court then reduced the sentence further to 60 months, citing 18 U.S.C. § 3553(a) factors such as youth, medical history, drug use, and limited criminal history.
- The government appealed only the additional reduction from 78 months to 60 months.

## Issues

1. Whether, after granting a government motion under 18 U.S.C. § 3553(e) and sentencing below a statutory mandatory minimum to reflect substantial assistance, a district court may further reduce the sentence based on non-assistance factors under 18 U.S.C. § 3553(a).

## Decision

- The Eighth Circuit vacated the 60-month sentence and remanded for resentencing.
- The court held that, once below-minimum authority is triggered by § 3553(e), the extent of any reduction below the mandatory minimum must be based solely on assistance-related considerations.
- The district court lacked authority to use other § 3553(a) factors to further reduce the sentence below the level justified by substantial assistance.

## Legal Principles

- A statutory mandatory minimum binds the sentencing court unless a statute provides a specific exception.
- Under 18 U.S.C. § 3553(e), a court may impose a sentence below a mandatory minimum only “so as to reflect” the defendant’s substantial assistance.
- Section 3553(a) factors do not authorize a sentence below a statutory minimum, except to the limited extent permitted by § 3553(e).
- When a court sentences below a mandatory minimum under § 3553(e), non-assistance considerations (e.g., personal characteristics unrelated to cooperation) cannot increase the size of the below-minimum reduction.

## Conclusion

The Eighth Circuit held that § 3553(e) permits a below-mandatory-minimum sentence only to the extent necessary to reflect substantial assistance; the district court therefore erred by further reducing the sentence based on unrelated § 3553(a) factors.


United States v. Williams, 474 F.3d 1130 (8th Cir. 2007)