United States v. Jackson, No. 19-6288 (4th Cir. 2020)
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After the district court reduced defendant's sentence under the First Step Act, the district court denied defendant's request for a sentence of 120 months' imprisonment, which would have allowed defendant to bank approximately 57 months toward a future sentence of incarceration if he violated his supervised release.
The Fourth Circuit affirmed and held that the district court did not abuse its discretion in reducing defendant's sentence to time served and ordering his immediate release, but denying his request to bank time for credit against future supervised release violations. In this case, the district court considered defendant's ability to bank time against future supervised release revocations in its analysis of the need to protect the public and the need for deterrence, two factors a court considers under 18 U.S.C. 3553(a) in imposing a sentence.
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