---
title: "United States v. Reed"
citation: "58 F.4th 816 (4th Cir. 2023)"
authority_id: "AUTH-CA4-REED-58-F4TH-816"
authority_type: "case"
jurisdiction: "federal_fourth_circuit"
precedential_status: "binding_in_ca4"
official_url: "https://www.ca4.uscourts.gov/opinions/197368.P.pdf"
url: "https://jason93.com/legal/federal-process/authorities/AUTH-CA4-REED-58-F4TH-816/"
legal_review: "2026-08-25"
links_checked: "2026-10-15"
links_available: 1
links_checked_count: 1
license: "CC BY 4.0"
---

# United States v. Reed

## Holdings used

- No reduction is mandatory merely because the existing sentence exceeds the revised statutory maximum; the record must show consideration of every nonfrivolous argument, and ambiguity can require remand.

## Material limitation

Binding only in the Fourth Circuit and only for the bounded procedural postures in the linked claims. Official amended published opinion reviewed. Reed expressly recognizes that Concepcion displaced Collington's mandatory-reduction rule; no reduction is guaranteed. A comprehensive commercial citator was not run.

## Official source and pinpoints

58 F.4th 816 (4th Cir. 2023), 58 F.4th 819–23: <https://www.ca4.uscourts.gov/opinions/197368.P.pdf>

## Linked claims

- `CLM-CIR4-002`


## Used in

- [Fourth Circuit Overlay](https://jason93.com/legal/federal-process/modules/95-circuit-overlays/fourth-circuit.md)
