United States v. Jackson, No. 19-2499 (3d Cir. 2020)
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In 2006, Harris pleaded guilty to possession with the intent to distribute five grams or more of a mixture and substance containing a detectable amount of cocaine base and stipulated to the quantity he possessed—33.6 grams. In 2019, Harris sought a reduction of his 210-month sentence under section 404 of the First Step Act of 2018, 132 Stat. 5222. The district court assumed that Harris was eligible but denied relief, stating that “neither the statutory penalties nor the advisory guidelines range would be affected if [he] were sentenced today given the stipulated drug quantity.”
Jackson was convicted in 2004 of the same crime. His indictment charged him with possession with the intent to distribute approximately 48 grams of crack. The jury convicted Jackson of possessing five grams or more, without any specific finding that he possessed 48 grams. In 2019, Jackson moved under section 404 for a reduction of his 300-month sentence. The district court denied relief, determining that he was ineligible.
The Third Circuit vacated as to Harris and reversed as to Jackson. Section 404 eligibility turns on a defendant’s statute of conviction, not on his possession of a certain quantity of drugs. Although Harris and Jackson each possessed more than 28 grams of crack, Harris pleaded guilty to and Jackson was convicted of possession of five grams or more; both can seek discretionary reductions of their sentences.
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