United States v. Easter, No. 19-2587 (3d Cir. 2020)
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In 2008, Easter was convicted of drug offenses involving crack cocaine and one firearms offense. The drug counts each carried a mandatory minimum penalty of 10 years’ imprisonment. The gun charge carried a mandatory consecutive minimum of five years’ imprisonment. The court determined that the guideline range for the drug offenses was 168-210 months, finding that Easter was responsible for possessing 343.55 grams of crack cocaine. The court added two levels because Easter obstructed justice and sentenced Easter to 228 months’ imprisonment--168 months on the drug offenses, consecutive to 60 months for the firearms offense. In 2014, Sentencing Guidelines Amendment 782 reduced the base offense levels of various drug quantities. The district court granted Easter a retroactive sentence reduction and imposed a sentence at the bottom of this range—135 months for the drug offenses and 60 consecutive months for the gun charge.
In 2018, the First Step Act made the Fair Sentencing Act retroactive so that an offense must involve 280 grams or more of crack cocaine to trigger the 10-years-to-life range. Easter sought resentencing. The government argued that eligibility turns not on the drug weight for which Easter was convicted (50 grams) but on the weight for which he was held responsible at sentencing (343.55 grams). The court explained that Easter was held responsible for 343.55 grams of crack cocaine so that his sentencing range is identical to the range he had following Amendment 782 and declined to exercise its discretion to resentence Easter without addressing Easter’s request that it consider his post-sentence rehabilitation or other section 3553(a) factors. The Third Circuit vacated. In considering a motion for a sentence reduction under the First Step Act, a court must consider anew all of the 18 U.S.C. 3553(a) factors.
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