“Reasons? We Don’t Need No Stinkin’ Reasons”: Why United States District Courts Should Be Required To Explain 18 U.S.C. § 3582(c)(2) Resentencing Decisions

A particular area of federal sentencing that remains problematic in the era of Sentencing Guidelines is resentencing. Whenever the Sentencing Guidelines are amended, convicted defendants whose “guideline ranges” are lowered by the United States Sentencing Commission can move for a reduction in their sentence under 18 U.S.C. § 3582(c)(2). However, district courts can deny motions for a sentence reduction. District court rulings are reviewed under an “abuse of discretion” standard and are rarely given a thoughtful explanation, leaving prisoners with no relief and no  explanation. This Comment examines the problems that exist with district courts’ failure to explain their rulings during § 3582(c)(2) sentence-modification proceedings. Specifically, this Comment discusses how the failure to explain resentencing decisions hinders meaningful appellate review, decreases the public trust in the criminal justice system, and obstructs the Sentencing Commission’s ability to revise the Sentencing Guidelines. Additionally, this Comment describes a model for what explanations from district courts should look like and how to require courts to provide one. This Comment concludes by suggesting that if district courts adequately explained their rulings during § 3582(c)(2) sentence-modification proceedings, each of the problems discussed herein would be alleviated and the number of § 3582(c)(2) motions would decrease over time, lessening the burden on the judiciary and prosecutors.