United States v. Howard, No. 19-2498 (8th Cir. 2020)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of a sentencing reduction to defendant under the First Step Act. Unlike the factual scenario in U.S. v. McDonald, 944 F.3d 769, 771 (8th Cir. 2019), the district court here addressed its discretion under the Act particularly, conducting the appropriate second step contemplated by the Act. Therefore, the court found that although the district court erred regarding defendant's eligibility under step one, remanding on the basis of that error would be an exercise in futility. In this case, the district court was the original sentencing court and thus was uniquely positioned to consider the many factors necessary in exercising its ultimate discretion. Furthermore, the court explained that the district court's plain statement regarding its decision not to exercise its discretion under the Act closes the matter.
Court Description: [Beam, Author, with Colloton and Benton, Circuit Judges] Criminal case - Sentencing. The district court erred in determining Howard was ineligible for First Step Act relief - see U.S. v. McDonald, 944 F.3d 769, 771 (8th Cir. 2019); here, however, unlike the case in McDonald, the district court went on to state that even if Howard was eligible for relief under the Act it would exercise its discretion and deny the motion; in light of the court's ruling, it would be futile to remand the case; the court's plain statement regarding its decision not to exercise its discretion under the First Step Act closes the matter. [ June 15, 2020 ]
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