United States v. Eulogio Ramiro Yoza Tigua, No. 19-10177 (11th Cir. 2020)Annotate this Case
In these separate appeals, the Eleventh Circuit held that defendants adjudicated guilty before but sentenced after the effective date of the First Step Act of 2018 may not qualify for relief under the amended statutory safety-valve provision. The court explained that the First Step Act states that its amendment of the statutory safety-valve provision "shall apply only to a conviction entered on or after the date of [its] enactment" on December 21, 2018. In this case, defendants had their convictions entered when the district court accepted their pleas of guilty before December 21, 2018, and thus they are ineligible for relief from the statutory mandatory-minimum sentence under the amended statutory safety-valve provision. The court also held that any error in the district court's denial of Defendant Castro's sentence for his minor role was harmless.