Reducing a Federal Sentence Cannot be Based on Factors Other Than Substantial Assistance to the United States

In United States v. Clawson , 650 F.3d 530 (4th Cir. 2011), an appeal was brought to the Fourth Circuit Court of Appeals by the federal government after a Federal District Court granted a motion under Federal Rule of Criminal Procedure 35(b) to reduce James Clawson's prison sentence for distribution