USA v. Walker

UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS
UNITED STATES OF AMERICA,
Plaintiff,
v.
RANDALL L. WALKER,
Defendant.
Case No. 18-cr-40087-JPG-1
MEMORANDUM AND ORDER
This case is before the Court on Defendant Randall Walker’s pro se motion to remove the
purity level enhancement in United States Sentencing Guideline Manual (“U.S.S.G.”) § 2D1.1
from his sentence (Doc. 87). Defendant pled guilty to one count of distribution of
methamphetamine in violation of 21 U.S.C. § 841(a)(1) and (b)(1)(C) and one count of being a
felon in possession of a firearm in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(2). Defendant
was sentenced to a total of 230 months in prison. His sentence was subsequently reduced to 210
months pursuant to 18 U.S.C. § 3582 Amendment 821. Now, he asks this Court to modify his
sentence due to “the change of the laws on the purity levels of methamphetamine to be no longer
valid” which makes “2D1.1 . . . no longer appliable in federal laws.”
This Court does not have inherent authority to modify a sentence. See United States v.
Anderson, 583 F.3d 504, 508 (7th Cir. 2009). 18 U.S.C. § 3582(c) provides three narrow
exceptions: (1) upon a motion by the Director of the Bureau of Prisons or by the defendant for
compassionate release, (2) as expressly permitted by statute or Federal Rule of Criminal
Procedure 35, or (3) when a defendant has been sentenced to a term of imprisonment based on a
sentencing range that has subsequently been lowered by the Sentencing Commission. Here, none
Case 4:18-cr-40087-JPG Document 94 Filed 12/17/25 Page 1 of 3 Page ID
#<pageID>

2
of the exceptions apply. Defendant does not seek a compassionate release,1 nor does he seek
relief under a particular statute or Rule 35. In addition, he was not sentenced to a term of
imprisonment based on a sentencing range that has subsequently been lowered.
Contrary to Defendant’s contention, U.S.S.G. § 2D1.1 is still applicable in federal
sentencing. See e.g., U.S.S.G. § 2D1.1 (2025). Defendant was sentenced under the 2018
Guideline Manual. At sentencing, the Court adopted the presentence investigation report’s
relevant conduct finding that Defendant distributed approximately 70.64 grams of ice, see PSR ¶
28, which yielded a base level offense of 30. Under the 2024 Guideline Manual,2 that relevant
conduct finding would still constitute a base level offense of 30. See U.S.S.G. § 2D1.1(c)(5)
(2024). And given that Defendant’s offense level was increased 4 points—2 points under
U.S.S.G. § 2D1.1(b)(1) because he possessed a dangerous weapon and 2 points under U.S.S.G. §
3C1.1 for attempting to escape from jail while in custody for the offense—to a total offense level
of 34 and Defendant had a criminal history category of IV, his sentencing guideline range would
still be 210 to 240 months.3 See Sentencing Table, U.S.S.G. Ch. 5 Pt. A (2024). His sentence of
210 months is within that guideline range. Therefore, the Court DENIES Defendant Randall
Walker’s pro se motion to remove the purity level enhancement in U.S.S.G. § 2D1.1 from his
sentence (Doc. 87).
IT IS SO ORDERED.
1 Defendant filed a motion for compassionate release on April 7, 2025. That motion is still pending.
2 The 2024 Guidelines were applicable on March 4, 2025, when Defendant filed his motion. The Court notes that,
under the 2025 Guidelines, effective November 1, 2025, the result would be the same.
3 At sentencing, Defendant’s criminal history category was determined to be V, yielding a guideline range of 235 to
240 months. He was sentenced to 230 months. On December 28, 2023, Defendant filed a motion for a sentence
reduction pursuant to 18 U.S.C. § 3582 Amendment 821. The Court found that the amendment lowered his criminal
history category to IV, making his amended guideline sentencing range 210 to 240 months. It reduced his sentence
to 210 months.
Case 4:18-cr-40087-JPG Document 94 Filed 12/17/25 Page 2 of 3 Page ID
#<pageID>

3
DATED: 	December 17, 2025
s/ J. Phil Gilbert
J. PHIL GILBERT
United States District Judge
Case 4:18-cr-40087-JPG Document 94 Filed 12/17/25 Page 3 of 3 Page ID
#<pageID>