United States v. Young, No. 19-4198 (2d Cir. 2021)
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Defendant appealed the district court's judgment granting in part and denying in part his motion for a sentence reduction pursuant to the First Step Act of 2018. The district court granted defendant's motion with respect to his conviction on Count One, a violation of 21 U.S.C. 841(b)(1)(A) for conspiracy to distribute and possess with intent to distribute 50 grams or more of crack cocaine, but denied the motion with respect to his conviction on Count Two, a violation of 21 U.S.C. 841(b)(1)(C) for distributing and possessing with intent to distribute an unspecified quantity of crack cocaine.
The Second Circuit concluded that, although defendant has been released from custody, his appeal is not moot. The court explained that if Count Two were a "covered offense" under the First Step Act, defendant would be eligible for a reduction in his term of supervised release on that count. Furthermore, there is more than a remote and speculative possibility that the district court on remand would grant such relief, and that possibility is enough to create a live controversy.
On the merits, the court concluded that a conviction for distributing and possessing with intent to distribute an unspecified quantity of crack in violation of 21 U.S.C. 841(b)(1)(C) is not a "covered offense" within the meaning of the First Step Act. Therefore, defendant is ineligible for a reduction in his sentence on Count Two under the First Step Act. The court rejected defendant's alternative argument, concluding that a court may not alter a sentence imposed on any count of conviction without express statutory authority to do so. Finally, the district court provided no explanation for why it left defendant's term of supervised release on Count One intact despite its decision to reduce his prison sentence on that count to time served. Accordingly, the court vacated defendant's term of supervised release on Count One and remanded. The court affirmed in all other respects.
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