US v. James Roane, Jr., No. 20-14 (4th Cir. 2022)
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In this consolidated appeal, defendants were convicted for drug-related murder under 21 U.S.C. Section 848(e)(1)(A), as well as distribution of crack cocaine under 21 U.S.C. Sections 841(a)(1) and 841(b)(1)(A)(ii). On appeal, the defendants argued that their drug-related murder conviction and their sentences of death and life imprisonment can no longer stand under the First Step Act. The defendants also claimed that their convictions under 21 U.S.C. Sections 841(a)(1) and 841(b)(1)(A)(ii) are "covered" offenses under the First Step Act and that their sentences should be reduced.
The Fourth Circuit rejected the defendant's appellate issues, affirming their convictions and sentences. The court explained that 21 U.S.C. § 848(e)(1)(A) is not a covered offense under the First Step Act as its penalties were not modified by the Fair Sentencing Act and that the defendants' sentences for the distribution charges were substantively and procedurally reasonable.
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