United States v. Junior Baptiste
CourtCourt of Appeals for the Eleventh Circuit
Date FiledNovember 5, 2026
Docket26-11563
StatusUnpublished
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Full Opinion
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NOT FOR PUBLICATION
In the
United States Court of Appeals
For the Eleventh Circuit
____________________
No. 26-11563
Non-Argument Calendar
____________________
UNITED STATES OF AMERICA,
Plaintiff-Appellee,
versus
JUNIOR JEAN BAPTISTE,
Defendant-Appellant.
____________________
Appeal from the United States District Court
for the Southern District of Florida
D.C. Docket No. 1:15-cr-20777-JEM-1
____________________
Before JORDAN, NEWSOM, and BRANCH, Circuit Judges.
PER CURIAM:
Junior Jean Baptiste, proceeding pro se, appeals the district
court’s denial of his motion to reduce his sentence based on
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2 Opinion of the Court 26-11563
Amendment 821, which added § 4C1.1 to the Sentencing Guide-
lines. Because § 4C1.1 does not apply to defendants who, like Bap-
tiste, received vulnerable-victim sentence adjustments, we affirm.
We review de novo the district court’s conclusion that a de-
fendant is (or is not) eligible for relief under 18 U.S.C. § 3582(c)(2).
United States v. Lawson, 686 F.3d 1317, 1319 (11th Cir. 2012). Under
that section, a district court may reduce a term of imprisonment
for a defendant “who has been sentenced to a term of imprison-
ment based on a sentencing range that has subsequently been low-
ered by the Sentencing Commission . . . if such a reduction is con-
sistent with applicable policy statements issued by the Sentencing
Commission.” 18 U.S.C. § 3582(c)(2).
In 2023, the Sentencing amended the Guidelines, adding a
new section, U.S.S.G. § 4C1.1 (2023). See U.S.S.G. app. C, amend.
821 (2023). “Pursuant to U.S.S.G. § 4C1.1, a defendant is eligible
for a two-point guidelines reduction if he has zero criminal history
points and meets a variety of other criteria.” United States v. Her-
nandez, 167 F.4th 1113, 1134 (11th Cir. 2026). One such criterion is
that “the defendant did not receive an adjustment under § 3A1.1.”
U.S.S.G. § 4C1.1(a)(9). Section 3A1.1 provides for a two-level in-
crease “[i]f the defendant knew or should have known that a victim
of the offense was a vulnerable victim” and another two-point in-
crease if the “offense involved a large number of vulnerable vic-
tims.” Id. § 3A1.1(b)(1)–(2).
Baptiste argues that he is eligible for a sentence reduction
because the newly enacted § 4C1.1 applies to zero-point offenders
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26-11563 Opinion of the Court 3
and applies retroactively. That’s true as far as it goes, but the new
section also explicitly limits its application to defendants who “did
not receive an adjustment under § 3A1.1.” Id. § 4C1.1(a)(9). That
disqualifies Baptiste, who received two separate two-level § 3A1.1
enhancements—one because he knew or should have known that
one of his victims was vulnerable, id. § 3A1.1(b)(1), and another be-
cause his offense involved a large number of vulnerable victims, id.
§ 3A1.1(b)(2). Order Den. Def.’s Mot. for Sentencing Reduction at
2, Dkt. No. 159. Baptiste counters that having received a § 3A1.1
enhancement doesn’t automatically take him out of § 4C1.1’s am-
bit, 1 but we read things differently: That section, by its own terms,
applies only to defendants who meet “all of the following criteria,”
U.S.S.G. § 4C1.1(a) (emphasis added), including that “the defend-
ant did not receive an adjustment under § 3A1.1,” id. § 4C1.1(a)(9).
That Baptiste received such an adjustment closes the case. The dis-
trict court did not err in denying Baptiste’s motion for a sentence
reduction based on § 4C1.1. 2
1 Baptiste looks to the United States Probation Office’s memorandum for sup-
port. To be sure, the USPO indicated that Baptiste is eligible for a § 4C1.1
reduction. But we think the USPO made a mistake when it failed to check the
box indicating that Baptiste originally received a § 3A1.1 enhancement. In any
event, the USPO’s memorandum does not compel us to ignore § 4C1.1’s plain
text. See United States v. Livesay, 525 F.3d 1081, 1089 (11th Cir. 2008) (“[D]istrict
courts are still required to correctly calculate the advisory Guidelines range.”).
2 Baptiste also argues that the district court erred by denying his motion for a
sentence reduction before it received reply briefing from him. Even if that
amounted to error, it was harmless: Nothing Baptiste could have written in
his reply brief would have changed the facts that (1) § 4C1.1 does not apply to
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4 Opinion of the Court 26-11563
AFFIRMED.
defendants who received § 3A1.1 adjustments, U.S.S.G. § 4C1.1(a)(9), and (2)
Baptiste received two such adjustments.