United States v. Felicia Massey, No. 18-3408 (8th Cir. 2020)
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The Eighth Circuit affirmed defendant's sentence imposed after she pleaded guilty to conspiring to distribute methamphetamine and cooperated with the government. The court held that there was no plain error at sentencing, and that defendant was ineligible for relief under the First Step Act.
The court rejected defendant's contention that the district court erroneously limited the factors that it considered in determining how much to reduce her sentence, holding that it is settled that the court was permitted to consider only assistance-related considerations. Furthermore, defendant has not established that the district court refused to consider any assistance-related consideration or that explicit consideration of her preferred factors is reasonably likely to have affected the sentence. Finally, the court held that defendant is not entitled to resentencing under the First Step Act, because her conviction was not entered on or after the date of enactment of the Act.
Court Description: [Colloton, Author, with Wollman and Benton, Circuit Judges] Criminal case - Sentencing. Where a district court reduces a sentence below the statutory minimum on the basis of cooperation, it is well-settled law that the court can only consider assistance-related considerations in deciding the extent of the reduction; even assuming that defendant's personal characteristics were relevant to the significance and usefulness of her assistance, defendant has not established that the court refused to consider any assistance-related consideration or that explicit consideration of her preferred factor was reasonably likely to have affected her sentence; defendant was not entitled to relief under the First Step Act as her conviction was not entered on or after the date of enactment of the Act.
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