Martin v. United States, No. 19-1701 (2d Cir. 2020)
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After the district court granted defendant's motion for resentencing under the First Step Act, it vacated its order and denied his motion as moot when the district court learned that defendant had completed serving his term of imprisonment for his 2005 drug offense and remained imprisoned only because he continued to serve two consecutive sentences imposed for offenses committed while in prison that he did not mention in his original application for re-sentencing.
The Second Circuit affirmed, holding that sentences are imposed separately for convictions on specific violations of criminal statutes and are aggregated only for administrative purposes. The court explained that, because sentences within judgments of conviction are otherwise final orders, they are modifiable only in limited circumstances. The court stated that the First Step Act permits such modification—a district court may "impose a reduced sentence" for a "covered offense." However, where an inmate, such as defendant in this case, has already served the term of imprisonment imposed for a "covered offense," the court held that the statute no longer permits relief. Therefore, defendant's motion is moot because the relief authorized by the First Step Act is no longer possible.
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