United States v. Flowers, No. 19-3742 (6th Cir. 2020)
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In 2004, Flowers was charged with possessing with intent to distribute over 50 grams of crack cocaine, 21 U.S.C. 841(b)(1)(A); because Flowers had two prior felony drug convictions, his minimum sentence was life in prison. Flowers pled guilty; the government agreed to allege only one prior drug offense, meaning his mandatory minimum would be 20 years. As a career offender, his Guidelines sentencing range was 262-327 months. The court found no basis supporting a departure and imposed a 262-month sentence. The Supreme Court subsequently held that the Guidelines are advisory. The Fair Sentencing Act of 2010 reduced the mandatory minimum for Flowers’ conviction to 10 years; the First Step Act of 2018 made those reductions retroactive if the 2010 law modified the statutory penalties.
Flowers sought resentencing, arguing that the Act modified his statutory minimum and that if he were sentenced today, he would not qualify as a career offender. HIs Ohio conviction no longer qualifies as a felony drug offense. Flowers noted his educational accomplishments and limited disciplinary record in prison. The government argued that Flowers’ Guidelines range was unchanged. The Sixth Circuit affirmed the denial of relief. Although it is unclear whether the district court indicated that Flowers was ineligible for a reduction because his Guidelines range did not change and the First Step Act only concerns statutory sentencing ranges, any error was harmless. The court considered all of his arguments and rejected them on the merits.
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