United States v. Birdine, No. 19-1782 (8th Cir. 2020)
Annotate this CaseThe Eighth Circuit reversed the district court's denial of defendant's motion for sentencing relief under the First Step Act of 2018. In resolving the matter, the district court did not have the benefit of the United States v. McDonald, 944 F.3d 769, 771 (8th Cir. 2019). Applying McDonald, the court held that defendant's conviction meets the three prerequisites of a covered offense, and defendant is eligible for relief under the First Step Act. Accordingly, the court remanded for the district court to consider whether to exercise its discretion under section 404 of the Act and reduce defendant's sentence.
Court Description: [Beam, Author, with Colloton and Benton, Circuit Judges] Criminal case - Sentencing. The district court erred in determining defendant was not eligible for relief under the First Step Act of 2018 - see, United States v. McDonald, 944 F.3d 769, 771 (8th Cir. 2019) - and the case is remanded to permit the district court to consider whether to exercise its discretion and reduce defendant's sentence.
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