US v. Leroy Goodwin, No. 20-7320 (4th Cir. 2022)Annotate this Case
In 2012, Defendant was sentenced to 219 months of incarceration for drug conspiracy charges involving powder and crack cocaine. Defendant moved for relief under the First Step Act, which reduced penalties under the Fair Sentencing Act. The District Court determined Defendant was eligible for relief under the First Step Act but denied Defendant's motion finding that his sentence was already at the statutory minimum.
The Fourth Circuit affirmed, albeit on alternate grounds. The court held that Defendant was ineligible for relief under the First Step Act. Section 404 of the First Step Act excludes defendants whose sentences previously were imposed in accordance with the Fair Sentencing Act. Defendant committed the offense before the Fair Sentencing Act became effective date but was convicted and sentenced after that date. His sentencing also came after the Supreme Court clarified, in Dorsey v. United States, 567 U.S. 260 (2012), that the Fair Sentencing Act was to be applied to pre-Act offenders, like Defendant, who had yet to be sentenced when that Act became effective. Thus, Defendant was ineligible for relief.
The court issued a subsequent related opinion or order on June 21, 2022.