United States v. Williams, No. 21-2401 (7th Cir. 2022)
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In 2001, Williams was convicted of conspiring to sell more than 50 grams of crack cocaine, 21 U.S.C. 846; distributing more than 50 grams of crack, 841(b)(1)(A)(iii); and distributing more than five grams of crack, 841(b)(1)(B)(iii). Sentenced to life imprisonment for Counts 1 and 2 and the statutory maximum 40-year term for Count 3, Williams sought a reduced sentence three times based on retroactive guidelines amendments, 18 U.S.C. 3582(c)(2). By 2014, Williams’s guidelines range had dropped to 235 from 293 months. The judge lowered his sentence to 360 months.
Williams filed his fourth sentence-reduction motion under the First Step Act, which made retroactive the Fair Sentencing Act's lower statutory penalties for crack offenses. The new ranges for Counts 1 and 2 were 60-480 months; Count 3 carried a maximum sentence of 240 months, 21 U.S.C. 841(b)(1)(B)(iii), (b)(1)(C) (2021). Judge Moody acknowledged Williams’s youth at the time of the offense, lack of significant criminal history, and near-perfect disciplinary record, but relied on the “reprehensibility of the crimes” without calculating new statutory ranges. He apparently assumed that the 2014 sentence conformed with new statutory maximums.
The Seventh Circuit vacated. The procedural requirements—calculating new penalties before deciding on the motion—apply to all First Step Act motions. The statutory ranges for all of Williams’s convictions changed between 2014 and the 2019 motion; the judge misstated the statutory penalty for Count 3. Williams was deprived of the benefit of any anchoring effect that the new ranges could have had on Judge Moody’s decision, which affects the fairness, integrity, and public reputation of the proceeding.
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