USA v. Bradley

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF OHIO
EASTERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
BRAD LEWIS BRADLEY,
Defendant.
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CASE NO. 5:19CR742
Judge John R. Adams
ORDER
Pending before the Court is Defendant Brad Bradley’s motion to reduce his sentence under
Amendment 821. 	Doc. 94. 	Upon review, the motion is DENIED.
Amendment 821, which became effective on February 1, 2024, applies retroactively. “Part
A of Amendment 821 limits the criminal history impact of ‘Status Points’ in Sentencing Guidelines
§ 4A. Prior to the enactment of Amendment 821, two “Status Points” were added when
determining a defendant's criminal history if the defendant committed his or her federal offense
while “under any criminal justice sentence,” including probation, parole, supervised release,
imprisonment, work release, or escape status. USSG § 4A1.1(d) (Nov. 2018). Now, pursuant to
Amendment 821 Part A, a defendant will be assessed one Status Point when determining his or
her criminal history if the defendant otherwise has seven or more criminal history points and
committed the instant offense under “any criminal justice sentence.” USSG § 4A1.1(e) (Nov.
2023). Part A effectively eliminates Status Points for defendants with six or fewer criminal history
points.
As Bradley was sentenced as a career offender, his guidelines range was derived from §
4B1.1, not § 4A1.1, and because Amendment 821 does not lower § 4B1.1's guidelines range, he
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fails to satisfy § 3582(c)(2)'s first requirement for a sentence reduction—i.e., the requirement that
that he must have “been sentenced to a term of imprisonment based on a sentencing range that has
subsequently been lowered by the Sentencing Commission.” 18 U.S.C. § 3582(c)(2); see United
States v. Simpson, No. 24-5272, 2024 WL 4337488, at *3 (6th Cir. Sept. 11, 2024) (“Amendment
821 also would not reduce [the defendant’s] applicable guidelines range. Amendment 821 affects
the calculation of criminal-history points, but [the defendant] would remain in criminal-history
category VI due to his career-offender status.”); cf. United States v. Williams, 607 F.3d 1123,
1125–26 (6th Cir. 2010) (holding that a career offender under § 4B1.1 did not receive a sentence
“based on a sentencing range that has subsequently been lowered by the Sentencing Commission”
and, as a result, was not eligible for a reduction under Amendment 706). 	As Bradley is ineligible
for relief, his motion is DENIED.1
Bradley requests in the alternative that the Court amend his PSR to remove the status points
at issue. 	However, as those points have no impact on Bradley’s criminal history category, the
Court declines to order any amendment to his PSR.2
The motion to reduce sentence is DENIED.
IT IS SO ORDERED.
January14, 2026 /s/John R.
Adams
JOHN R. ADAMS
UNITED STATES DISTRICT JUDGE
1 Contrary to Bradley’s assertion, the Court is not required to review the § 3553(a) factor after finding him
ineligible for relief. 	Such a review would be a waste of judicial resources.
2 Bradley also requests that the PSR add the names of the mothers of his children. 	The Court can find no basis to
order such an amendment and declines to do so.
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