United States v. Moore, No. 21-2431 (7th Cir. 2022)

The Seventh Circuit affirmed the decision of the district court reducing Defendant's life sentence to a term of 420 months for his conviction of conspiring to distribute at least fifty grams of crack cocaine and of being a felon in possession of a firearm, holding that Defendant was not entitled to relief on his claims of error.

Because Defendant had four prior drug convictions under Illinois law the district court imposed a mandatory term of life in prison. More than a decade later, Defendant moved for a sentence reduction under the First Step Act of 2018. The district court reduced Defendant's life sentence but decided not to apply Mathis v. United States, 479 U.S. 500 (2016), under which Defendant's guideline and statutory ranges would have been reduced. The Seventh Circuit affirmed, holding (1) there is no reason that any further consideration of Defendant's Mathis argument would have changed the court's determination; (2) Defendant was not entitled to relief on his disparity argument; and (3) the district court's comments about the weapons found at Defendant's home were not improper.