United States v. Sutton, No. 19-2009 (7th Cir. 2020)
Annotate this CaseIn 2008, Sutton pled guilty to distributing cocaine base and carrying a firearm during a drug-trafficking crime. The district court sentenced Sutton to the then statutory minimum 15 years’ imprisonment. In announcing the sentence, the court emphasized that it had no authority to reduce the sentence further or amend it later, except on the government’s motion, and that the court’s authority had been so limited since the Sentencing Reform Act of 1984. The First Step Act of 2018 subsequently permitted a defendant sentenced for a covered offense (which includes Sutton’s crack cocaine charge) to move for the district court to impose a reduced sentence. The district court denied Sutton’s motion. On Sutton’s pro se appeal, the Seventh Circuit recruited counsel for supplemental briefing on the narrow question of the proper vehicle for a First Step Act motion--how the First Step Act interacts with the Sentencing Reform Act. The Seventh Circuit then affirmed the denial of relief. The First Step Act is its own procedural vehicle; the only limits on the district court’s authority under the First Step Act come from the interpretation of the First Step Act itself, which gives the court broad discretion. In this case, the district court did not abuse its discretion.
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