United States v. Curtis, No. 21-2615 (7th Cir. 2023)
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Curtis was convicted in 2000 for his part in a crack-cocaine distribution enterprise, including related shootings. The indictment included drug conspiracy counts, firearm counts, and an 18 U.S.C. 924(c) count for carrying a firearm in relation to a drug trafficking crime. Curtis’s PSR grouped the drug counts and grouped the firearms counts (for causing the death of another with a firearm in furtherance of the conspiracy) separately, with terms of imprisonment to run consecutively. Section 924(c) convictions feature a five-year mandatory consecutive minimum sentence and are always grouped separately. Curtis did not object to the groupings. Curtis was sentenced to life imprisonment plus a concurrent term of 480 months on the drug counts; two consecutive life sentences on the firearms counts; and another consecutive 60 months on the 924(c) count.
Under the 2018 First Step Act, the district court reduced Curtis's term of imprisonment for the drug conspiracy counts to 293 months but concluded that resentencing was not authorized for the other counts. The Seventh Circuit affirmed, rejecting an argument that the court was incorrect to rely rigidly on the grouping rules and that Curtis’s whole sentence should be treated as “a single sentencing package.” While a court does have discretion under the Act to reduce an aggregate sentence, even if part of that sentence rests on offenses that are neither covered by the Act nor grouped with a covered offense, Curtis’s consecutive sentences for the firearms convictions were not part of a package. They were not “covered offenses” and “could not be grouped” with a covered offense.
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