United States of America v. Jonas Michael

Miami, Florida pro se Defendant unsuccessfully represented him self when charged with unlawful transportation of firearms.



Jonas Michel, proceeding pro se, appeals the district court's order denying his motion for a sentence reduction pursuant to 18 U.S.C. § 3582(c)(2) based on Part A of Amendment 821 to the United States Sentencing Guidelines, a retroactive amendment eliminating or reducing criminal history status points for certain offenders. He argues that the district court abused its discretion in denying him a sentence reduction because it: (1) failed to justify the increased upward variance resulting from his reduced Guidelines range; (2) failed to cite the United States Sentencing Commission's policy reasons for Amendment 821; (3) relied on criminal history already reflected in his Guidelines range; and (4) did not mention his history of mental health issues and substance abuse or his efforts at rehabilitation in declining to reduce his sentence.

Imprisonment for a term of 42 months, supervised release for 3 years, $100 special assessment



Affirmed