United States v. Sparkman, No. 17-3318 (7th Cir. 2020)
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Sparkman belonged to a gang that was responsible for murders, kidnappings, and robberies. Sparkman was directly involved in at least two kidnappings in which firearms were used to threaten the victims. He was convicted of federal offenses, including racketeering, drug crimes, and two counts of using a firearm to commit a kidnapping, 18 U.S.C. 924(c). In 2012, Sparkman was sentenced to the mandatory minimum--42 years' imprisonment.
Before the First Step Act of 2018, the second violation of section 924(c) triggered a much higher 25‐year mandatory minimum, even if the two counts were asserted in a single indictment. The First Step Act amended section 924(c) so that only a second violation committed after a prior conviction for the same offense will trigger the 25‐year minimum. These amendments apply to an offense committed before enactment “if a sentence for the offense has not been imposed as of such date of enactment.” 18 U.S.C. 924 note). Sparkman’s sentence was pending on appeal on the date of enactment. The Seventh Circuit rejected his First Step Act petition; “a sentence is ‘imposed’ in the district court, regardless of later appeals.”
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