United States v. Martin, No. 08-2622-cr., 2009 WL 2524003 (2d Cir. Aug. 19, 2009)
Martin appealed his 180 months sentence for a cocaine offense, which sentence was substantially below the sentencing range of 262 to 362 months recommended by the Guidelines. The sole issue on appeal was whether the district court erred in declining to further reduce Martin's sentence to reflect his attempts to cooperate witht the Government. Although acknowledging that the district court had the authority to depart downward based on non-5K cooperation, the Second Circuit ultimately rejected Martin's appeal because the district court's "reasons were thoroughly explained and manifestly reasonable." Thus, the Second Circuit found no error in Martin's sentence -- in other words, a high level of deference to the district courts.