Case Explained: United States of America v. Shane Seizys

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-06-24 The eighth-circuit affirmed the district court’s denial of Shane Seizys’s motion for a sentence reduction under 18 U.S.C. § 3582(c)(2). The court held that Seizys was ineligible for relief because his sentence was not “based on” a subsequently lowered Sentencing Guidelines range, as required by the statute and interpreted in *Hughes v. United States*, 584 U.S. 675 (2018). The court applied the standard that a defendant’s sentence is based on a Guidelines range only if that range was a relevant part of the analytical framework used to determine the sentence or approve the plea agreement. The Eighth Circuit found that the district court did not rely on the Guidelines range but instead imposed the agreed-upon 348-month sentence primarily to allow Seizys to avoid a mandatory consecutive sentence of up to 100 years under 18 U.S.C. § 924(c) for brandishing a firearm during a crime of violence. The court determined that the district court’s decision was anchored in the concessions made by the Government to dismiss thirteen other counts and the need to avoid the severe statutory penalties Seizys faced at trial, rather than the specific Guidelines calculation. Consequently, the fact that the agreed-upon sentence was numerically close to the original Guidelines range did not render it “based on” that range for the purposes of a reduction. As a result of this ruling, the district court’s order denying the sentence reduction remains in effect, and Seizys must serve his current 348-month term without reduction based on Amendment 821 to the U.S. Sentencing Guidelines. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.