United States v. Collington, No. 19-6721 (4th Cir. 2021)
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In 2010, defendant was sentenced to 30 years' imprisonment after pleading guilty to various federal narcotics and firearm offenses. In 2019, defendant moved for a reduced sentence under section 404(b) of the First Step Act, contending that his sentence was ten years longer than the current statutory maximum.
The Fourth Circuit vacated the district court's denial of defendant's motion for a reduced sentence under the Act, concluding that, in light of United States v. Chambers, 956 F.3d 667 (4th Cir. 2020), the district court may only exercise its discretion to reduce or not reduce any given sentence after faithfully considering a number of resentencing factors. The court held that one of those criteria—as is typically true in sentencing—is the applicable statutory maximum sentence. The court explained that, if sentenced today, defendant would be subject to the sentencing ranges set forth in 21 U.S.C. 841(b)(1)(C). And as the district court correctly stated in its order, that range sets a maximum mandatory term of 20 years' imprisonment. Therefore, the district court erred by not resentencing defendant to, at most, 20 years' imprisonment. The court also held that when a court exercises discretion to reduce a sentence, the imposition of the reduced sentence must be procedurally and substantively reasonable. On remand, the court instructed the district court to comply with its substantive and procedural reasonableness requirements, including its requirement that it adequately explain its sentencing decision.
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