United States v. Williams, No. 19-5803 (6th Cir. 2020)
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In 2005, Williams pled guilty to possession with intent to distribute 50 grams or more of crack cocaine, 21 U.S.C. 841(a). Williams’s PSR calculated a Guidelines range of 262-327 months' imprisonment. The government filed a notice of a prior felony drug conviction under 21 U.S.C. 851, which made Williams subject to a mandatory minimum sentence of 20 years and a maximum term of life imprisonment. The court sentenced Williams to 262 months.
The 2018 First Step Act authorized district courts to reduce defendants’ sentences for certain drug offenses, 132 Stat. 5194. Although the Act reduced Williams’s mandatory minimum sentence to 10 years, his Guidelines’ range remained the same. Williams sought resentencing under the Act, citing his good conduct in prison: he had not failed a single drug test, had helped 13 other prisoners earn their GEDs, and had held the same job for over eight years. The district court explained that it had considered the 18 U.S.C. 3553(a) sentencing factors and concluded that “the 262-month within guideline sentence originally imposed remains sufficient and necessary to protect the public from future crimes of the defendant, to provide just punishment, and to provide deterrence.” The court did not address Williams’s post-conviction conduct.
The Sixth Circuit vacated. Williams's post-conviction conduct occurred after his initial sentencing, so the record for his initial sentence provides no indication of the court’s reasoning.
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