Sentencing Guidelines » Chapter 4

U.S.S.G. § 4C1.1

Adjustment for Certain Zero-Point Offenders

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(a)      Adjustment.—If the defendant meets all of the following criteria:

(1)       the defendant did not receive any criminal history points from Chapter Four, Part A;

(2)       the defendant did not receive an adjustment under §3A1.4 (Terrorism);

(3)       the defendant did not use violence or credible threats of violence in connection with the offense;

(4)       the offense did not result in death or serious bodily injury;

(5)       the instant offense of conviction is not a sex offense;

(6)       the defendant did not personally cause substantial financial hardship;

(7)       the defendant did not possess, receive, purchase, transport, transfer, sell, or otherwise dispose of a firearm or other dangerous weapon (or induce another participant to do so) in connection with the offense;

(8)       the instant offense of conviction is not covered by §2H1.1 (Offenses Involving Individual Rights);

(9)       the defendant did not receive an adjustment under §3A1.1 (Hate Crime Motivation or Vulnerable Victim) or §3A1.5 (Serious Human Rights Offense);

(10)     the defendant did not receive an adjustment under §3B1.1 (Aggravating Role); and

(11)     the defendant was not engaged in a continuing criminal enterprise, as defined in 21 U.S.C. § 848;

decrease the offense level determined under Chapters Two and Three by 2 levels.

(b)      Definitions and Additional Considerations.—

(1)       “Dangerous weapon,” “firearm,” “offense,” and “serious bodily injury” have the meaning given those terms in the Commentary to §1B1.1 (Application Instructions).

(2)       “Sex offense” means (A) an offense under (i) chapter 109A of title 18, United States Code; (ii) chapter 110 of title 18, not including a recordkeeping offense; (iii) chapter 117 of title 18, not including transmitting information about a minor or filing a factual statement about an alien individual; or (iv) 18 U.S.C. § 1591; or (B) an attempt or a conspiracy to commit any offense described in subparagraphs (A)(i) through (iv) of this definition.

(3)       In determining whether the defendant’s acts or omissions resulted in “substantial financial hardship” to a victim, the court shall consider, among other things, the non-exhaustive list of factors provided in Application Note 4(F) of the Commentary to §2B1.1 (Theft, Property Destruction, and Fraud).

Commentary

Application Note:

1.       Application of Subsection (a)(6).—The application of subsection (a)(6) is to be determined independently of the application of subsection (b)(2) of §2B1.1 (Theft, Property Destruction, and Fraud).

Historical Note: Effective November 1, 2023 (amendment 821). Amended effective November 1, 2024 (amendments 830 and 831); November 1, 2025 (amendment 836). 

 

 

Notes of Decisions
Cited in 152 cases (152 in the last 5 years), 2024–2026 · leading case: United States v. Taeyan Williams, 130 F.4th 177 (4th Cir. 2025).
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United States v. Taeyan Williams, 130 F.4th 177 (4th Cir. 2025). · cites it 3× “Second, he asks us to remand for the district court to apply newly promulgated U.S.S.G. § 4C1.1 to his sentence. And third, Scott contends the district court improperly delegated judicial powers to the United States Probation Office in imposing substance abuse and mental health…”
United States v. Sardar Ashrafkhan, 129 F.4th 980 (6th Cir. 2025). · cites it 4× “After Ashrafkhan’s sentencing, the United States Sentencing Commission promulgated a new guideline, USSG § 4C1.1, to provide a two-point reduction in the offense level for defendants who received no criminal history points at sentencing, otherwise referred to as “zero- point…”
United States v. Shefiu Animashaun Hanson, 124 F.4th 1013 (6th Cir. 2025). · cites it 8× “Hanson moved under the newly created U.S.S.G. § 4C1.1 of the United States Sentencing Guidelines, which retroactively applies to defendants sentenced before the Amendment went into effect on November 1, 2023.”
United States v. Gonzalez-Loera, 135 F.4th 856 (9th Cir. 2025). · cites it 7× “GONZALEZ-LOERA SUMMARY *** Criminal Law The panel affirmed the district court’s denial of Roberto Gonzalez-Loera’s motion for a sentence reduction under the new zero-point offender provision of U.S.S.G. § 4C1.1. Section 4C1.1 allows a court to adjust a defendant’s offense level…”
United States v. Victor Chichande, 113 F.4th 913 (9th Cir. 2024). · cites it 2× “”); and (2) in any event, a remand is appropriate because he qualifies for a retroactive reduction under U.S.S.G. § 4C1.1 (“zero- point offender reduction”).”
United States v. Aurelio Cervantes, 109 F.4th 944 (7th Cir. 2024). · cites it 2× “U.S.S.G. § 4C1.1(a) (amended Nov. 1, 2023).”
United States v. Jose Medina De La Cruz, 135 F.4th 1127 (8th Cir. 2025). · cites it 2× “1(a) was promulgated, the tenth criterion required that “the defendant did not receive an adjustment under § 3B1.”
United States v. Shakira Martinez, 137 F.4th 858 (3rd Cir. 2025). “For the foregoing reasons, we will vacate Martinez’s sentence and remand with instructions that she be resentenced in a manner consistent with U.S.S.G. § 4C1.1 and U.S.S.G. § 1B1.10(b).”
United States v. Jones, 136 F.4th 272 (5th Cir. 2025). · cites it 13× “On January 31, 2024, the Probation Office filed a Retroactive Amendment 821 Worksheet, which found that Jones qualified for a USSG § 4C1.1 two-point reduction. On February 12, 2024, the U.”
United States v. Morales (5th Cir. 2024). · cites it 10× “After Morales’s sentencing, Amendment 821 to the Sentencing Guidelines added a new guideline, USSG § 4C1.1. USSG Supp. to App. C, Amendment 821, Part B, Subpart 1, at 236–37 (Nov.”
United States v. Michael Milchin (3rd Cir. 2025). · cites it 8× “He unsuccessfully sought a retroactive application of the new offense-level reduction under U.S.S.G. § 4C1.1 for “zero-point offenders.”
United States v. Michael Milchin (3rd Cir. 2025). · cites it 8× “He unsuccessfully sought a retroactive application of the new offense-level reduction under U.S.S.G. § 4C1.1 for “zero-point offenders.”
Show all 152 citing cases →
— U.S.S.G. §4C1.1(10) — 1 case
United States v. King (D.D.C. 2025).
— U.S.S.G. §4C1.1(3) — 1 case
United States v. Kelly (D.D.C. 2024).
— U.S.S.G. §4C1.1(4) — 1 case
Tyler Makes Him First v. United States of Am. (D.S.D. 2025).
— U.S.S.G. §4C1.1(7) — 1 case
United States v. Bell (D.D.C. 2025).
— U.S.S.G. §4C1.1(A) — 1 case
United States v. Richard Shaw (4th Cir. 2024).
— U.S.S.G. §4C1.1(a) — 43 cases
United States v. Taeyan Williams, 130 F.4th 177 (4th Cir. 2025). “Second, he asks us to remand for the district court to apply newly promulgated U.S.S.G. § 4C1.1 to his sentence. And third, Scott contends the district court improperly delegated judicial powers to the United States Probation Office in imposing substance abuse and mental health…”
United States v. Aurelio Cervantes, 109 F.4th 944 (7th Cir. 2024). “U.S.S.G. § 4C1.1(a) (amended Nov. 1, 2023).”
United States v. Gonzalez-Loera, 135 F.4th 856 (9th Cir. 2025). “GONZALEZ-LOERA SUMMARY *** Criminal Law The panel affirmed the district court’s denial of Roberto Gonzalez-Loera’s motion for a sentence reduction under the new zero-point offender provision of U.S.S.G. § 4C1.1. Section 4C1.1 allows a court to adjust a defendant’s offense level…”
United States v. Jose Medina De La Cruz, 135 F.4th 1127 (8th Cir. 2025). “1(a) was promulgated, the tenth criterion required that “the defendant did not receive an adjustment under § 3B1.”
United States v. Tenney (D.D.C. 2024).
— U.S.S.G. §4C1.1(a)(1) — 11 cases
United States v. Bauer (D.D.C. 2024).
Akintola v. United States (S.D.N.Y. 2024).
United States v. Najar-Celis (10th Cir. 2024).
United States v. Michael Anthony Sheppard (11th Cir. 2025).
United States v. King (D.D.C. 2025).
— U.S.S.G. §4C1.1(a)(10) — 24 cases
United States v. Sardar Ashrafkhan, 129 F.4th 980 (6th Cir. 2025). “After Ashrafkhan’s sentencing, the United States Sentencing Commission promulgated a new guideline, USSG § 4C1.1, to provide a two-point reduction in the offense level for defendants who received no criminal history points at sentencing, otherwise referred to as “zero- point…”
United States v. Gonzalez-Loera, 135 F.4th 856 (9th Cir. 2025). “GONZALEZ-LOERA SUMMARY *** Criminal Law The panel affirmed the district court’s denial of Roberto Gonzalez-Loera’s motion for a sentence reduction under the new zero-point offender provision of U.S.S.G. § 4C1.1. Section 4C1.1 allows a court to adjust a defendant’s offense level…”
United States v. Aurelio Cervantes, 109 F.4th 944 (7th Cir. 2024). “U.S.S.G. § 4C1.1(a) (amended Nov. 1, 2023).”
United States v. Jose Medina De La Cruz, 135 F.4th 1127 (8th Cir. 2025). “1(a) was promulgated, the tenth criterion required that “the defendant did not receive an adjustment under § 3B1.”
United States v. Michael Milchin (3rd Cir. 2024).
— U.S.S.G. §4C1.1(a)(3) — 8 cases
United States v. Yang (D.D.C. 2024).
United States v. Alexandre Ovadia (11th Cir. 2025).
Chambers v. United States (S.D.N.Y. 2024).
Ferguson v. United States (E.D. Wis. 2024).
Harper v. United States (W.D. Wis. 2024).
— U.S.S.G. §4C1.1(a)(4) — 2 cases
United States v. Yang (D.D.C. 2024).
United States v. Morgan (9th Cir. 2026).
— U.S.S.G. §4C1.1(a)(6) — 9 cases
United States v. Shefiu Animashaun Hanson, 124 F.4th 1013 (6th Cir. 2025). “Hanson moved under the newly created U.S.S.G. § 4C1.1 of the United States Sentencing Guidelines, which retroactively applies to defendants sentenced before the Amendment went into effect on November 1, 2023.”
United States v. Suarez (5th Cir. 2025).
United States v. Unigwe (9th Cir. 2025).
United States v. Martins Inalegwu (3rd Cir. 2025).
United States v. Mizrahi (9th Cir. 2025).
— U.S.S.G. §4C1.1(a)(7) — 16 cases
United States v. Danny Aument (3rd Cir. 2024).
United States v. Botello Vargas (5th Cir. 2025).
United States v. Castillo-Pena (9th Cir. 2025).
United States v. Noel Rivera (8th Cir. 2024).
United States v. Salazar (10th Cir. 2024).
— U.S.S.G. §4C1.1(b)(2) — 1 case
United States v. Khan (10th Cir. 2025).
— U.S.S.G. §4C1.1(b)(2)(A) — 1 case
United States v. Gregory Gallagher (11th Cir. 2026).
— U.S.S.G. §4C1.1(b)(3) — 2 cases
United States v. Shefiu Animashaun Hanson, 124 F.4th 1013 (6th Cir. 2025). “Hanson moved under the newly created U.S.S.G. § 4C1.1 of the United States Sentencing Guidelines, which retroactively applies to defendants sentenced before the Amendment went into effect on November 1, 2023.”
United States v. Paul Harmon (3rd Cir. 2025).
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