US v. Danny Smith, No. 21-6829 (4th Cir. 2023)
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Defendant is fifteen years into his twenty-year prison sentence for conspiring to distribute crack cocaine. A few years after he was sentenced, Congress passed the Fair Sentencing Act, which reduced the crack-to-powder cocaine disparity. If sentenced today, Smith’s mandatory minimum would be half his current sentence. Under the retroactivity provisions of the First Step Act, Defendant moved for a sentence reduction to time served. The district court denied his motion, determining that twenty years remained appropriate. Defendant appealed, claiming among other things that the district court miscalculated his Guidelines range and that our recent decision in United States v. Swain, 49 F.4th 398 (4th Cir. 2022), reveals substantive errors in the district court’s analysis.
The Fourth Circuit affirmed. The court explained that “The Fair Sentencing Act and First Step Act, together, are strong remedial statutes, meant to rectify disproportionate and racially disparate sentencing penalties.” The district court considered these remedial aims, as well as all other nonfrivolous arguments, before exercising its broad discretion to deny sentencing relief. Further, while the court recognized the disparity between Defendant’s new Guidelines range and his current sentence, the district court properly explained why it remained substantively reasonable.
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