United States v. Shields, No. 19-2717 (3d Cir. 2022)
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In 2008, Shields was convicted of crack cocaine offenses. His PSR classified him as a career offender based on his 1995 Maryland conviction for robbery with a deadly weapon and his 2002 Maryland conviction for conspiracy to distribute crack cocaine. His Guidelines range was 360 months to life. Shields objected to an enhancement for the use of a firearm in connection with the offense and to the drug quantity attributed to him, which exceeded that found by the jury. The court declined to rule on the objections because neither would change his Guidelines range given his career-offender status. The court sentenced Shields to 360 months in prison. The Fair Sentencing Act of 2010 subsequently reduced the disparities between the sentencing schemes for crack and powder cocaine. Shields became eligible for resentencing in 2018, based on the First Step Act.
Shields requested a full sentencing hearing or to file a sentencing memorandum with supplemental documentation “to present evidence of his post-sentence rehabilitation” and to dispute his career-offender status. He believed one of his prior convictions was no longer a predicate offense, and renewed his objections to the enhancements for firearm use and drug weight. The court denied his request for a full hearing and reduced his sentence to 262 months, stating “[t]he First Step Act does not permit the court to consider other statutory or sentencing guideline amendments enacted since" the offense. The Third Circuit vacated. The district court had the discretion to consider Shields’s arguments concerning intervening changes in law and abused its discretion in denying him the opportunity to make other arguments in favor of a downward variance.
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