Sentencing

The Court affirmed the defendant’s convictions and sentence under 18 U.S.C. § 924(c). While the First Step Act was enacted while the defendant’s appeal was pending, the Court held that its provisions on mandatory minimums did apply retroactively to cases pending on direct appeal.

The Court affirmed the defendant’s reduced sentence under the First Step Act where the sentencing court sentenced the defendant to time served, and not less time than he had already served, in order to prevent the defendant from “banking” the excess time and applying it in a potential future revocation of his supervise release.

The Court affirmed the defendant’s sentence as procedurally reasonable. The sentencing court did not err by considering the defendant’s false testimony under the 3553 factors despite not finding that she obstructed justice under USSG 3C1.1.

The Court affirmed the defendant’s sentence, holding that the defendant’s prior conviction for loitering under Pennsylvania law was not “loitering” or an “offense similar to” loitering under the Guidelines because the Pennsylvania offense requires proving criminal intent.

In a unanimous decision, the Supreme Court held a defendant’s prior conviction under state law qualifies as a “serious drug offense” under the ACCA if the defendant’s conduct involves “manufacturing, distributing, or possessing with intent to manufacture or distribute, a controlled substance” as spelled out under the statute. In doing so, the Court rejected a categorical approach that would require courts to match the defendant’s state offenses to a “generic offense.”

The Supreme Court held that allowing a state appellate court to reweigh the aggravating and mitigating factors in a capital case under Clemons v. Mississippi is a permissible remedy after a finding on collateral review that the sentence court failed to consider mitigating factors in violation of Eddings v. Oklahoma.

In a unanimous opinion, the Supreme Court held that a defendant has preserved his ability to appeal a sentence as substantively unreasonable as long as the sentence ultimately imposed was longer than the sentence he requested.

Despite the significant amount of discretion granted to sentencing courts, the Court held that the district court’s downward variance of 80% from a Guidelines range of 85 years in prison to 17 years in prison was substantively unreasonable based on the Court of Appeals finding that the district court improperly second-guessed the defendant’s state of mind, created an unwarranted disparity between the defendants, and placed too much weight on mitigating factors.

The Court held that the sentencing court committed plain and reversible error when it relied on the defendant’s “bare arrest record” in determining a sentence, as the sentencing court had only cited the Defendant’s “extensive criminal history” without adequately distinguishing between adjudications, convictions, and mere arrests. 

The Court held that a defendant is eligible to request a sentence reduction under the First Step Act as long as he was convicted of a “covered offense,” regardless of how his sentence was calculated under the Guidelines. What matters is the offense as defined by the statute-of-conviction.