United States v. Smithers, No. 19-5849 (6th Cir. 2020)
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In 2006 Smithers pleaded guilty to two aiding-and-abetting counts involving cocaine. The government had notified him that it would seek life imprisonment because he had four prior “felony drug offenses,” 21 U.S.C. 841(b)(1)(A), 851. In the plea deal, the government withdrew its reliance on three of the convictions. Smithers’s remaining “felony drug offense” triggered a mandatory-minimum sentence of 240 months. Smithers also qualified as a “career offender” under the Sentencing Guidelines; his guidelines range was 262-327 months. The court imposed a 262-month sentence. T
he 2010 Fair Sentencing Act increased the quantity of crack cocaine necessary to trigger Smithers’s 20-year mandatory minimum from 50 grams to 280 grams. Because Smithers had pleaded guilty to possessing 50 grams, his mandatory-minimum sentence would have dropped 10 years. The 2018 First Step Act made the Fair Sentencing Act retroactive and gives district courts discretion over whether to reduce this type of sentence. The probation office found that Smithers did not qualify for relief under the Act. His status as a career offender kept his guidelines range the same even after the reduction in his mandatory-minimum sentence.
The district court found that Smithers was “eligible for consideration of a reduced sentence under 18 U.S.C. 3582(c)(1)(B)” but held that Smithers did not warrant that discretionary relief. The Sixth Circuit affirmed. The court declined to address whether the Sentencing Reform Act, 18 U.S.C. 3742(a), limited Smithers’s appeal; the government waived that argument. The court did not abuse its discretion when denying Smithers a reduced sentence.
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