United States v. Mapp, No. 11-3214 (8th Cir. 2012)
Annotate this CaseOn February 27, 2010 and March 25, 2010, Defendant sold cocaine base to a confidential informant. Pursuant to a plea agreement, Defendant pleaded guilty to two counts of distribution of at least five grams of cocaine base. Before his September 29, 2011 sentencing hearing, Defendant submitted a memoranda urging the district court to apply the Fair Sentencing Act (FSA), which had taken effect on August 3, 2010. Retroactive application of the FSA would have had the effect of reducing Defendant's statutory maximum term of imprisonment. The district court denied Defendant's request, consistent with the Eighth Circuit Court of Appeals' decision in United States v. Sidney, which held that the FSA was not retroactive, even as to defendants who were sentenced after the enactment of the FSA where their criminal conduct occurred before the enactment. The U.S. Supreme Court subsequently abrogated Sidney and ruled that the FSA's provision applies to offenders who committed a crack cocaine crime before August 3, 2010 but were not sentenced until after August 3. The Eighth Circuit accordingly vacated Defendant's sentence and remanded for resentencing.
Court Description: Criminal case - Crack sentence vacated and case remanded in light of Dorsey v. United States, No. 11-5683, 2012 WL 2344463 (U.S. June 21, 2012).
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