United States v. Potts, No. 15-12311 (11th Cir. 2021)
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In 2006, Potts pled guilty to conspiracy to distribute at least 50 grams of crack cocaine, 21 U.S.C. 841(a)(1), (b)(1)(A)(iii) and 846. In a consolidated case, Potts pled guilty to conspiracy to manufacture, possess with intent to distribute, and distribute at least 50 grams of crack cocaine and at least 5 kilograms of powder cocaine, sections 841(a)(1), (b)(1)(A)(iii) and 846; and being a felon in possession of a firearm and ammunition, 18 U.S.C. 922(g) and 924(e). The court imposed three concurrent 240-month sentences.
In 2019, Potts sought a sentence reduction under the First Step Act, 132 Stat. 5194. The district court found Potts was ineligible because he was not sentenced for a “covered offense” and that section 3553(a)'s factors indicate that a sentence reduction is unwarranted. In 2020, while Potts’ appeal was pending, the court granted Potts compassionate release under 18 U.S.C. 3582(c)(1)(A), after analyzing the 3553(a) factors and finding compelling reasons: Potts’ serious medical conditions rendered him uniquely vulnerable to COVID-19. The court imposed an additional 37-month supervised release term—the unserved portion of his original prison sentence—to be served on “home confinement” before serving his original, concurrent supervised release terms.
The Eleventh Circuit then affirmed the denial of his 2019 motion. The 2020 motion rendered the issue moot with respect to his incarceration but not with respect to supervised release. The court’s refusal to reduce Potts’ supervised release terms was not an abuse of its discretion.
This opinion or order relates to an opinion or order originally issued on March 8, 2016.
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