United States v. Lemons, No. 21-5313 (6th Cir. 2021)
Annotate this Case
In 2009, Lemons pleaded guilty as a felon in possession of a firearm and was sentenced to 180 months’ imprisonment, based on the Armed Career Criminal Act (ACCA), which requires the imposition of a 180-month mandatory minimum sentence if the defendant has “at least three previous convictions for certain ‘violent’ or drug-related felonies.” The district court concluded that Lemons' three Tennessee convictions for aggravated burglary qualified as ACCA predicate offenses. The Sixth Circuit affirmed and later ordered the reinstatement of that sentence after the district court granted Lemons 28 U.S.C. 2255 relief.
After serving approximately seven years of his sentence, Lemons sought a sentence reduction under 18 U.S.C. 3582(c)(1)(A)(i), citing the risk presented by COVID-19 given his medical condition (hypothyroidism), his lengthy sentence, and his progress towards rehabilitation. The district court denied the motion, finding that Lemons did not present extraordinary and compelling reasons warranting a sentence reduction, and declining to consider 18 U.S.C. 3553(a)’s factors. The Sixth Circuit affirmed, noting Lemons’ access to the COVID-19 vaccine. Rehabilitation alone is not a basis for relief and Lemons’ mandatory minimum sentence is not a post-sentencing factual development that can serve as an extraordinary and compelling reason to reduce a sentence.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.