USA v. Lewis et al

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
UNITED STATES OF AMERICA 	CRIMINAL ACTION
VERSUS 	NUMBER 17-55
JOHNNY TRIPLETT 	SECTION "L"
ORDER AND REASONS
The Court has before it a Motion for Sentence Reduction filed by pro se Defendant Johnny
Triplett. R. Doc. 852. At the Court’s direction, the Government filed a response to Defendant’s
motion. R. Doc. 854. Having considered the briefing, in light of the applicable law and record
facts, the Court will DENY Defendant’s motion.
I. 	Background and Present Motion
Defendant pleaded guilty in August, 2021, to a one count Superseding Bill of Information
charging him with conspiracy to distribute and possess with the intent to distribute 500 grams or
more of cocaine hydrochloride and 100 grams or more of heroin. R. Doc. 525. In March, 2022, he
was sentenced to 151 months incarceration followed by a four-year term of supervised release. R.
Doc. 639. Defendant now seeks a reduction of that sentence. R. Doc. 852.
As an initial matter, the Court notes that Defendant’s motion is styled as a Motion to
Reduce Sentence Pursuant to 18 U.S.C. § 3582(c)(B)(2). Because § 3582(c)(B)(2) does not exist,
the Government in its opposition construes Defendant’s motion as a motion for compassionate
release pursuant to § 3582(c)(1)(A). R. Doc. 854 at 1. However, Defendant appears to press
arguments for a reduction in his sentence under both § 3582(c)(1)(A)(i) and § 3582(c)(2). The
Court will thus address each section in turn.
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II. 	Section 3582(c)(1)(A)(i)
18 U.S.C. § 3582(c)(1)(A)(i) permits the Court to reduce a defendant’s sentence where
“extraordinary and compelling reasons warrant such a reduction.” However, this statute requires
the defendant to have “fully exhausted all administrative rights” prior to bringing his motion before
a court. 18 U.S.C. § 3582(c)(1)(A). Defendant has attached to his motion the Warden’s denial of
his request for compassionate release. R. Doc. 852-2. But Defendant raised in that request only
one of the arguments Defendant now raises in his motion before the Court. Accordingly, Defendant
has not exhausted his administrative remedies as to the remainder of his arguments, and the Court
cannot consider them with respect to Defendant’s motion for a sentence reduction pursuant to
§ 3582(c)(1)(A)(i).
As 	to 	the remaining 	argument 	properly 	before the Court, 	Defendant 	asserts 	that
extraordinary and compelling reasons warrant a reduction in his sentence because “As of
November 1, 2025, new amendments went into effect for low-level individuals in high-quantity
drug cases. The new cap [sic] are as follows: A cap at offense level 32 for a defendant receive a
mitigating role adjustment. A cap at offense level 30 for a defendant who receive a minor role
adjustment. If sentenced my base level offense would be 30/32; Not 34.” R. Doc. 852-2 at 1.
Construing Defendant’s motion liberally, Defendant argues that he should have been assigned a
mitigating or minor role adjustment with respect to his crime of conviction, and as such that the
referenced amendment to the United States Sentencing Guidelines, if applied retroactively, would
have lowered his applicable Guidelines sentencing range.
However, Defendant pressed the argument that he should be assigned a mitigating or minor
role in the crime in his objections to the Presentence Investigation Report. R. Doc. 595. The Court
carefully considered his arguments during Defendant’s sentencing hearing and denied them for the
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reasons stated on the record. See R. Doc. 714 at 3–5. Defendant does not raise any new argument
or compelling grounds for this Court to reconsider its determination that Defendant did not warrant
the application of a mitigating or minor role adjustment. Accordingly, Defendant fails to present
extraordinary 	or 	compelling 	reasons 	justifying 	a 	reduction 	of 	his 	sentence 	under
§ 3582(c)(1)(A)(i).
III. 	Section 3582(c)(2)
18 U.S.C. § 3582(c)(2) does not contain an exhaustion requirement and permits the Court
to reduce a sentence “in the case of a defendant who has been sentenced to a term of imprisonment
based on a sentencing range that has subsequently been lowered by the Sentencing Commission
pursuant to 28 U.S.C. 994(o) . . . after considering the factors set forth in section 3553(a) to the
extent that they are applicable, if such a reduction is consistent with applicable policy statements
issued by the Sentencing Commission.” The only argument Defendant raises concerning an
amendment to the Sentencing Guidelines is the same addressed supra. As the Court has
determined, Defendant is not eligible for a mitigating or minor role adjustment. As such, the
November 1, 2025, amendment to the guidelines lowering the total offense level for defendants
assigned a mitigating or minor role in the crime of conviction is inapplicable to Defendant.
Defendant has not shown that he is entitled to a reduction in his sentence under § 3582(c)(2).
IV. 	Conclusion
Accordingly, for the foregoing reasons;
IT IS ORDERED that Defendant’s Motion for Sentence Reduction, R. Doc. 852, is
DENIED.
New Orleans, Louisiana, this 12th day of January, 2026.
United States District Judge
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