Sentencing/First Step Act – Section 403 of the First Step Act, which reduces the mandatory minimum for convictions under 18 U.S.C. § 924(c), does not apply retroactively to cases pending on direct appeal when the First Step was enacted.
The Court held that the First Step Act’s provisions reducing the mandatory minimums did not apply to the defendant’s mandatory minimum sentence under 924(c). Citing other circuits, the Fourth Circuit held that the defendant’s sentence had already been “imposed” for the purposes of Section 403 of the First Step Act, once the district court announced the final judgment, rather than when it becomes final after appeal.