A simple solution to the pipeline problem?

The Second Circuit’s powerful decision late yesterday in Williams explaining its Crosby approach to plain error (discussed here, now available on-line here), as well as the cert. petition in the Eleventh Circuit’s Rodriguez decision (discussed here), spotlight dramatically the disparate circuit approaches to some of the pipeline cases.  And considering that plain error is only one of the challenging pipeline issues facing the circuit courts, I have lately been thinking about whether there is some easier way to deal with all the pipeline cases.

Here is my latest thought.  How about this blanket rule to be applied to all non-final cases at any stage of appellate review: if the original sentence was at the guidelines minimum, a strong (but rebuttable) presumption that resentencing is appropriate; if the original sentence was above the guidelines minimum, a solid (but rebuttable) presumption that resentencing is not needed?

In other words, forget about plain error, harmless error, Rule 28(j) letters, etc; let’s just have, in the name of greater uniformity, one blanket rule for all non-final cases still in the system.  If this is a good idea, could Congress or the USSC make it happen?