United States v. Richardson, No. 22-6748 (4th Cir. 2024)
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In this case, the United States Court of Appeals for the Fourth Circuit considered whether a district court can reduce a sentence for both covered and noncovered offenses under the First Step Act if they were sentenced as a package. The defendant, Nathaniel Richardson, was originally sentenced to two concurrent terms of life imprisonment for conspiracy to distribute crack cocaine and heroin and for engaging in a continuing criminal enterprise. After the passage of the First Step Act, Richardson sought a sentence reduction. The district court reduced the sentence for the crack cocaine distribution offense but left the sentence for the continuing criminal enterprise offense undisturbed.
The Fourth Circuit vacated the district court's ruling and remanded the case for further proceedings. The appellate court held that the district court has the discretion to reduce both covered and noncovered offenses under the First Step Act if they function as a package. The court reasoned that since district judges often sentence on multiple counts as an interconnected process, they should be given the discretion to reconfigure the sentencing plan to ensure it remains adequate to satisfy the statutory sentencing factors. The court further noted that the sentencing package doctrine is applicable here because when one count of a package is remanded, the district judge must be given the discretion to review the efficacy of what remains in light of the original plan. The case was remanded for the district court to decide whether the counts functioned as a package, and if so, to resentence accordingly.
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