United States v. Woods, No. 19-5685 (6th Cir. 2020)
Annotate this CaseIn 2001, Woods pled guilty to possessing and conspiring to possess with intent to distribute 50 grams or more of cocaine base, aiding and abetting possession with intent to distribute cocaine and to distribute marijuana, and possessing a firearm in furtherance of a drug trafficking crime. The parties stipulated to Woods’s possession of 125 grams of crack cocaine, .73 grams of powder cocaine, and 660.1 grams of marijuana. Under the then-Guidelines, the PSR recommended a range of 121-151 months of imprisonment and an additional mandatory 60-month consecutive term for the firearm charge. The district court sentenced Woods to 121 months plus the consecutive 60- month sentence. In 2008, in response to Guidelines amendments, the district court reduced Woods’s sentence from 181 months to 120 months. Woods began his supervised release in 2015. While on release, he tested positive for cocaine and marijuana and pled guilty to new felony state charges—trafficking in controlled substances, possessing a handgun, and tampering with physical evidence. The court revoked Woods’s supervised release and imposed a 37-month sentence. Woods moved, under the 2018 First Step Act, 132 Stat. 5194, to reduce his sentence. The Sixth Circuit affirmed the denial of Woods’s motion. Although he is currently serving a post-revocation sentence, Woods is eligible for consideration of a reduction but is not entitled to one. The court adequately considered factors warranting denial of a reduction: respecting the law, protecting the public, and adequately deterring similar conduct.
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