Case Citator › United States v. Lance Williams

United States v. Lance Williams

Is it still good law? What later courts have actually done to this case.

Abrogated
Court
Fourth Circuit
Citation
808 F.3d 253
Decided
Confirmed treatments
2
Flagged citations read
32 of 32
Citing cases (total)
32
Treatment dates
2016–2018
Abrogated
A reviewed court treats this case as abrogated by later authority. United States v. Lance Williams's sentence reduction eligibility rule was abrogated by the Supreme Court in Koons v. United States. Williams treated Amendment 780 as making a defendant eligible after a substantial assistance departure below a mandatory minimum.
More on how this was screened

Koons held that the sentence must actually have been based on a later lowered Guidelines range; the policy statement cannot itself create eligibility. United States v. Davenport later identified Koons as foreclosing Williams's approach. Williams's separate rule about a Fourth Circuit panel's authority over earlier panel decisions was not disturbed. All 32 flagged citations have been read; the two adverse treatments are listed below.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

32 later cases cite United States v. Lance Williams; 32 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on United States v. Lance Williams?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Abrogated

  • The Supreme Court displaced Williams's rule that Amendment 780 itself establishes eligibility for a sentence reduction after a substantial assistance departure below a statutory minimum.

    Koons v. United States · Supreme Court of the United States · filed

    But policy statements cannot make a defendant eligible when §3582(c)(2) makes him ineligible.
    Read the full opinion on CourtListener →

Declined to follow

  • The Middle District of Alabama rejected the Williams majority's eligibility rule and adopted its dissent's contrary reading of Amendment 780.

    United States v. Sawyer · M.D. Ala. · filed

    Having carefully considered the divergent decisional holdings, the court is persuaded that the position taken by the Fourth Circuit’s chief judge in Williams is the better reasoned one. See 808 F.3d at 263-666 (Traxler, C.J.). Where a federal crime carries a statutory mandatory minimum sentence, only Congress can make an exception to its imposition.
    Read the full opinion on CourtListener →

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