United States v. Murphy, No. 20-1411 (3d Cir. 2021)
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In 2009, Murphy was convicted of distribution and possession with the intent to distribute heroin and 50 grams or more of cocaine base and conspiracy to do the same. The jury specifically found that the weight of the cocaine base attributable to Murphy was 50 grams or more, triggering the highest mandatory minimum sentence (10 years). With a career-offender designation, Murphy’s Guidelines sentencing range was 360 months to life. He was sentenced to 360 months.
In 2019, Murphy sought resentencing under Section 404(b) of the First Step Act. A PSR addendum preserved the drug amounts and the career-offender designation and decreased Murphy’s sentencing range to 262–327 months. Murphy objected to the drug amounts and the career-offender designation, arguing that the jury had only specifically found that he was responsible for 50 grams of cocaine base instead of the 595 grams in the PSR and that his Maryland second-degree assault convictions were no longer career-offender status predicates. The district court concluded that the First Step Act did not permit reconsideration of either factor and sentenced Murphy to 210 months’ imprisonment—the high end of the range without the career-offender designation.
The Third Circuit vacated. The district court correctly refused to reconsider Murphy’s attributable drug amounts but Murphy was entitled to an accurate calculation of the Guidelines range at the time of resentencing, including whether he qualified for the career-offender enhancement based on the law at the time of resentencing.
The court issued a subsequent related opinion or order on August 4, 2021.
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