United States v. Mitchell, No. 20-2493 (3d Cir. 2022)
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In 2015, Mitchell was convicted of drug-and gun-related offenses, including two counts of possession of a firearm in furtherance of a drug-trafficking crime, and aiding and abetting such possession, 18 U.S.C. 924(c)(1). After the enactment of the 2018 First Step Act, the Third Circuit vacated Mitchell’s 1,020-month sentence, finding that the sentencing court violated his due process rights.
The Third Circuit held that the provisions of the First Step Act do apply to Mitchell’s resentencing. The Act is ambiguous; it applies, prospectively, to all offenses committed after the Act’s enactment but, retroactively, “to any offense that was committed before the date of enactment of this Act, if a sentence for the offense has not been imposed as of [that] date.” The court chose to interpret it broadly to allow the Act’s provisions to apply to a defendant whose pre-Act-unconstitutional sentence was vacated after the Act’s enactment. Because Mitchell’s sentence was fully vacated, he was an unsentenced defendant after the enactment of the Act and entitled to benefit from it.
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