United States v. Savani, No. 11-4359 (3d Cir. 2013)
Annotate this CaseEach defendant was convicted of a cocaine base (crack) related offense. The government moved for a downward departure due to substantial assistance by each. The district court granted the departure and sentenced the defendant below the statutory mandatory minimum. Shortly thereafter, the Fair Sentencing Act of 2010 (FSA) became law, and the United States Sentencing Commission approved Amendment 750, a retroactive amendment, which lowered the base offense levels applicable to crack cocaine offenses. Defendants moved to further reduce their sentences. Although the qualifying amount of cocaine base necessary to trigger the mandatory minimum sentence has been increased, the government argued that the duration of the statutorily required minimum sentence has not changed so that the defendants are still subject to the mandatory minimum sentence. The district courts denied defendants’ motions. The Third Circuit vacated and remanded, holding that defendants, who are convicted of crack cocaine offenses and whose original sentences were below the mandatory minimum applicable to them because of substantial assistance to the government, are not barred for policy reasons from seeking a reduction of sentence pursuant to 18 U.S.C. 3582(c)(2).
The court issued a subsequent related opinion or order on May 6, 2013.
The court issued a subsequent related opinion or order on May 7, 2013.
The court issued a subsequent related opinion or order on June 10, 2013.
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