USA v. Coach, No. 22-2267 (3d Cir. 2023)
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In this case, Daniel Coach and Clifton Junius, who were both involved in a drug distribution operation, appealed the denials of their motions for sentence reduction under the First Step Act. They argued that their convictions for intentional killing in furtherance of a continuing criminal conspiracy were "covered offenses" under the Act, and hence, they were eligible for sentencing relief for their convictions under that statute. The United States Court of Appeals for the Third Circuit disagreed with the appellants' arguments, holding that drug-related murder under 28 U.S.C. § 848(e)(1)(A) is not a covered offense under the First Step Act.
The appellants also argued that their murder and drug charges on which they were sentenced were interdependent, so they were eligible for sentence reduction under the sentencing package doctrine. The court disagreed, stating that the sentencing package doctrine does not apply to this case because the sentences imposed on Coach and Junius for murder in furtherance of a continuing criminal enterprise were imposed independently from their cocaine base distribution charges and were not part of a sentencing package. The court affirmed the lower court's decision denying the motions for sentence reduction.
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