United States v. Keitt, No. 21-13 (2d Cir. 2021)
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When a district court denies a defendant's motion under 18 U.S.C. 3582(c)(1)(A) in sole reliance on the applicable 18 U.S.C. 3553(a) factors, it need not also determine whether the defendant has shown extraordinary and compelling reasons that might (in other circumstances) justify a sentence reduction.
Defendant moved to reduce his 60-month sentence to time served under section 3582(c)(1)(A), but the district court denied the motion. In considering defendant's motion, the district court recognized the health challenges he might face from the COVID-19 pandemic while incarcerated. The district court also relied on the applicable factors listed in 18 U.S.C. 3553(a), including the seriousness of defendant's offense, the harm it had caused his community, and the need to avoid unwarranted sentencing disparities among similarly situated criminal defendants. Accordingly, the court affirmed the district court's judgment.
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