The defendant is serving a sentence, which is more than three centuries long for his role in 13 gunpoint robberies committed when he was 19 years old. He filed a motion for compassionate release pursuant to the First Step Act. The defendant sought relief, pointing to the recent changes to the mandatory minimum laws and … Read more
The Third Circuit revisited its recent opinion in United States v. Easter and the First Step Act. First, the Third Circuit joined the Eleventh Circuit in holding that, under the Act, sentencing courts are “bound by a previous finding of drug quantity that could have been used to determine the movant’s statutory penalty at the … Read more
The Third Circuit ran into a novel issue surrounding the First Step Act in United States v. Hart. The Act was passed in 2018, and it made retroactive certain reductions in mandatory-minimum sentences that were passed into law in 2012. Under the Act, eligible prisoners could petition to reduce their sentences per the 2012 reductions. … Read more
In United States v. Easter, the 3rd Circuit broke with the holdings of several other circuits and ruled that, when deciding whether to exercise its discretion under § 404(b) of the First Step Act to reduce a defendant’s sentence, including the term of supervised release, the district court must consider all of the § 3553(a) … Read more
In United States v. Birt, the Third Circuit held that a conviction under 21 U.S.C. § 841(a)(1) and (b)(1)(C) is not a “covered offense” within the meaning of the First Step Act.
In these consolidated cases, the defendants sought discretionary reductions of their sentences pursuant to § 404 of the First Step Act. The District Courts denied relief, and on appeal, the primary issue was § 404 eligibility. The Third Circuit remanded both cases, holding that, by looking at the statutes of conviction, the defendants were eligible … Read more