United States v. Burden, No. 20-1059 (2d Cir. 2021)
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The Second Circuit affirmed the district court's denial of defendant's motion for a sentence reduction pursuant to the First Step Act of 2018. Defendant was one of the leaders of a Norwalk, Connecticut-based organization that trafficked powder and crack cocaine. In 2003, defendant was convicted of multiple drug- and racketeering-related crimes and sentenced to life imprisonment.
The court agreed with the district court that defendant is ineligible for First Step Act relief because his existing sentence was imposed in accordance with the relevant terms of the Act. In this case, defendant's 2015 plenary resentence, the operative sentence in this appeal, was imposed after the effective date of the crack cocaine provisions in section 2 of the Fair Sentencing Act of 2010, and the district court sentenced defendant in accordance with these provisions at the 2015 hearing.
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