United States v. Hill

Summary

The court held that Hill was legally ineligible for a sentence reduction under Amendment 821 because he lacked status points, had one criminal-history point, and his offense involved a death. It further held that Hill's challenge to the application of the cross-reference was outside the scope of a sentence-reduction motion because the motion could address only retroactive guideline amendments. The court declined to consider additional claims raised for the first time on appeal and dismissed the appeal as frivolous.