United States v. McDonald, No. 19-1221 (8th Cir. 2019)
Annotate this CaseDefendant appealed from the district court's denial of his motion for a sentence reduction under the First Step Act of 2018, which made retroactive the lower penalties for cocaine base offenses established by the Fair Sentencing Act. The Eighth Circuit held that the district court erred by finding that defendant was ineligible for relief. In this case, defendant's conviction for distributing two ounces of cocaine base was a covered offense under section 404 of the Act and thus he was eligible for a sentence reduction. Accordingly, the court reversed and remanded.
Court Description: Kelly, Author, with Melloy and Stras, Circuit Judges] Criminal case - Sentencing. McDonald committed an offense covered by the First Step Act, and the matter is remanded for further proceedings.
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