8th Circuit upholds denial of sentence reduction for man convicted of aiding assault on federal…
United States v. William Corbine
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8th Circuit upholds denial of sentence reduction for man convicted of aiding assault on federal officer, saying the judge properly weighed criminal history, offense seriousness, and prison conduct.
Why it matters
The Eighth Circuit affirmed the district court's decision to deny William Corbine a reduced sentence, even though he was eligible for one under a 2023 update to the federal sentencing guidelines. The district court had discretion to weigh factors including Corbine's criminal history, the serious nature of his offense (directing his sister to shoot at an officer during a high-speed chase), and his disciplinary record in prison. The appeals court found no abuse of that discretion.
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- Offense conduct
- Prison behavior
What happens next
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Decision issued Jul 17, 2026
Unpublished opinion
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Jul 17, 2026 · Unpublished opinion
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William Corbine pleaded guilty in 2017 to aiding and abetting an assault on a federal officer and a firearms offense, receiving a total sentence of 60 months on the assault charge plus a mandatory consecutive 120 months on the firearms charge. In 2024, he asked the court to reduce the 60-month portion of his sentence based on a retroactive 2023 change to the federal sentencing guidelines that eliminated two criminal history points previously added when a defendant committed an offense while already under a criminal justice sentence. Under the updated guidelines, his advisory sentencing range for the assault offense would have been 41 to 51 months instead of the original 51 to 63 months, so he sought a reduction to 48 months. The district court agreed Corbine was eligible for a reduction but denied the motion after weighing the relevant factors under federal sentencing law. It pointed to his prior criminal history, the seriousness of the offense, and disciplinary violations he incurred while serving his sentence. On appeal, Corbine argued the district court abused its discretion by ignoring his rehabilitation efforts, such as earning his GED, and by giving too much weight to factors that were already considered at his original sentencing. The Eighth Circuit rejected each of Corbine's arguments. The court explained that when a judge reviews a sentence-reduction motion, the sentencing guidelines expressly instruct the court to consider the defendant's history and characteristics, the nature and circumstances of the offense, and post-sentencing conduct. The court found that all three of those considerations, including the public safety concern raised by directing someone to fire a gun at an officer in a residential area during a high-speed chase, legitimately supported the district court's decision to leave the original sentence in place. The appeals court also noted that once a defendant is found eligible for a reduction at step one of the required analysis, the district court has substantial discretion at step two in deciding whether to actually grant one. Because the district court considered the appropriate factors and did not act unreasonably in weighing them, the Eighth Circuit affirmed the denial. The opinion does not reflect any dissent from the three-judge panel.
CITATION AND RECORD
Record source: CourtListener
United States Court of Appeals For the Eighth Circuit ___________________________ No. 25-1384 ___________________________ United States of America, lllllllllllllllllllllPlaintiff - Appellee, v. William Corbine, also known as William Tate Corbine, lllllllllllllllllllllDefendant - Appellant. ____________ Appeal from United States District Court for the District of South Dakota - Western ____________ Submitted: March 16, 2026 Filed: July 17, 2026 [Unpublished] ____________ Before COLLOTON, Chief Judge, GRUENDER and KOBES, Circuit Judges. ____________ PER CURIAM. In 2017, William Corbine pleaded guilty to aiding and abetting an assault on a federal officer and the discharge of a firearm during the commission of a crime of violence. In 2024, Corbine moved for a sentence reduction based on an amendment to the sentencing guidelines that reduced the number of criminal history points scored for defendants who commit an offense while serving any criminal justice sentence. The district court* concluded Corbine was eligible for a reduction, but denied the motion based on Corbine’s criminal history, the circumstances and seriousness of the offense, and disciplinary violations that Corbine incurred while serving his current sentence. Corbine appeals, and we affirm. I. When Corbine was sentenced in 2017, the district court calculated a total criminal history score of ten points under the sentencing guidelines. The court scored two points for commission of the offense while serving a criminal justice sentence. See USSG § 4A1.1(d) (Nov. 2016). Corbine’s advisory guideline range for the assault offense was 51 to 63 months’ imprisonment; the firearms offense carried a mandatory consecutive sentence of ten years’ imprisonment. The district court sentenced Corbine to 60 months’ imprisonment for the assault offense and 120 months on the firearms offense, to be served consecutively. In 2023, the Sentencing Commission amended USSG § 4A1.1 to eliminate the provision adding two criminal history points for the commission of a federal offense while under a criminal justice sentence. USSG App. C., Amend. 821. Under the amended guideline, the court adds a single point if the defendant receives seven or more criminal history points and committed the instant offense while under any criminal justice sentence. Id. The Commission made this amendment retroactive. USSG § 1B1.10(d), p.s., comment. (n.7). Corbine moved to reduce his sentence under 18 U.S.C. § 3582(c)(2) based on the amendment to USSG § 4A1.1. He pointed out that if his sentence had been * The Honorable Camela C. Theeler, United States District Judge for the District of South Dakota. -2- calculated under the current guidelines, then his advisory range for the assault offense would have been 41 to 51 months rather than 51 to 63 months. Corbine sought a reduction in sentence from 60 months to 48 months on the assault offense. The government agreed that Corbine was eligible for a reduction, but opposed the motion on the ground that the sentencing factors under 18 U.S.C. § 3553(a) and Corbine’s post-sentencing conduct did not support a reduction. The district court denied the motion. The court determined that Corbine was eligible for a reduction, but concluded that the original sentence was appropriate after considering “all of Corbine’s conduct, including the seriousness of the instant offenses and the issues he has had while in custody, along with the other 3553(a) factors.” On appeal, Corbine argues that the district court abused its discretion by ignoring his rehabilitation efforts and giving undue weight to his history and characteristics, the nature and circumstances of the offense of conviction, and his post-sentencing conduct. A district court’s decision to deny a sentence reduction is reviewed for abuse of discretion. United States v. Boyd, 835 F.3d 791, 792 (8th Cir. 2016). II. A district court must follow a two-step inquiry to determine whether a defendant’s sentence should be reduced pursuant to a retroactive amendment to the sentencing guidelines. Dillon v. United States, 560 U.S. 817, 824-25 (2010). The court first determines whether a defendant is eligible for a reduction under the amended guidelines. Id. at 821. In the second step, the court may grant a reduction within the amended guidelines range “if it determines that one is warranted” after considering the applicable section 3553(a) factors. Id. at 822. -3- The parties do not dispute that Corbine was eligible for a sentence reduction under the amended USSG § 4A1.1(e). Once a district court has determined that a defendant is eligible under step one, it has “substantial discretion” under step two in deciding whether to reduce the sentence. United States v. Burnell, 2 F.4th 790, 792 (8th Cir. 2021). Corbine contends that the district court abused its discretion at step two because it improperly weighed the factors under 18 U.S.C. § 3553(a). First, Corbine contends the district court placed undue weight on his prior criminal history and characteristics. The district court determined that Corbine’s criminal history, including a prior conviction for burglary and possession of controlled substances, supported denying his motion for a reduced sentence. Corbine argues that his prior criminal history was already accounted for in his original sentence, so the district court should not have considered his criminal history again when reviewing his motion for a sentence reduction. But the guidelines instruct the district court to consider the § 3553(a) factors, including “the history and characteristics of the defendant,” when determining whether a sentence reduction is warranted. See USSG § 1B1.10, p.s., comment. (n.1 (B)(i)). The district court has wide latitude to weigh these factors, and there was no abuse of discretion in considering Corbine’s criminal history as a factor that weighed against a reduction. Second, Corbine argues the district court abused its discretion by placing undue weight on the nature and circumstances of his offense. The district court determined that the circumstances of the offense raised public safety concerns, because Corbine directed his sister to fire a gun at an officer during a high-speed chase in a residential area. The guidelines instruct the district court to consider “the nature and circumstances of the offense” and the need for the sentence imposed “to protect the public from further crimes of the defendant.” See USSG § 1B1.10, p.s., comment. (n.1 (B)(i)); 18 U.S.C. § 3553(a)(1), (a)(2)(B). The district court raised legitimate concerns about public safety, and the court did not abuse its discretion in determining that the circumstances of the offense weighed in favor of a 60-month sentence. -4- Third, Corbine contends that the district court placed undue weight on his post- sentencing conduct. A court may consider a defendant’s post-sentencing conduct when reviewing a motion for a sentence reduction. USSG § 1B1.10, p.s., comment. (n.1(B)(iii)); United States v. Darden, 910 F.3d 1064, 1068 (8th Cir. 2018). The court found that Corbine had taken some positive actions, including obtaining his GED,
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