United States v. McDonald, No. 19-7668 (4th Cir. 2021)
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The Fourth Circuit vacated the district court's orders partially granting defendants' motions for sentence reductions pursuant to Section 404 of the First Step Act. In each case, the district court granted defendants' motions pursuant to a standard "AO 247" form in which the district court checked the box for "granted" and reduced the term of supervised release on each of defendants' sentences by one year. However, the district court did not alter the underlying sentences.
Applying de novo review, the court held that the district court failed to provide individualized explanations to each defendant in the face of newly presented, post-sentencing conduct. The court agreed with defendants that their cases are factually similar to the defendants' cases in United States v. Martin, 916 F.3d 389 (4th Cir. 2019), and thus the court should vacate the district court's orders with instructions for the district court to provide individualized explanations consistent with Martin. The court explained that the presentation of post-sentencing mitigation evidence in each of defendants' motions is sufficient to rebut the Legree presumption that the district court, in fact, considered all of the relevant evidence.
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