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U.S. v. Pillow, No. 98-4516 (4th Cir.) (191 F.3d 403) (September 7, 1999) (Judge Karen J. Williams)

Here the Court held that the starting point for calculating a sentence reduction based on USSG § 5K1.1 is the statutory mandatory minumum, not the low end of the Guideline range that would have been applicable but for the mandatory minimum.

Judge Butzner dissented, stating that "Section 3553(e) does not ...

 

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