United States v. Woodson, No. 19-6976 (4th Cir. 2020)Annotate this Case
By an interim order dated April 2, 2020, the Fourth Circuit vacated the district court's decision denying defendant's motion for a reduced sentence, ruled that defendant was eligible for relief under the First Step Act, and remanded for the district court to consider whether to exercise its discretion under the Act to impose a reduced sentence. This opinion explains the reasons for the court's order.
The court held that when the Fair Sentencing Act changed the quantities of crack cocaine to which 21 U.S.C. 841(b)(1)(C) applies, it "modified" the statutory penalties of that subsection for purposes of crack cocaine offenders within the meaning of the First Step Act. In this case, defendant's sentence under subsection 841(b)(1)(C) was imposed for a "covered offense," and he is eligible for a First Step Act sentence reduction. Accordingly, the court vacated the district court's judgment and remanded for further proceedings.
This opinion or order relates to an opinion or order originally issued on April 2, 2020.