United States v. Rendon, No. 19-2515 (8th Cir. 2020)
Annotate this CaseThe Eighth Circuit vacated the district court's denial of defendant's motion for a sentence reduction, holding that the district court erred in relying on a drug-quantity figure that did not match what was attributed to defendant at sentencing. In this case, defendant seeks to take advantage of Amendment 782, which retroactively lowered the base offense levels for most drug-quantity offenses. The district court assumed that the correct drug amount was 136.08 kilograms and denied the motion. However, the district court had already rejected this figure earlier at defendant's original sentencing. Therefore, the amount the district court used was at odds with its previous factual finding and the remedy for this error is remand for reconsideration.
Court Description: [Stras, Author, with Kelly and Wollman, Circuit Judges] Criminal case - Sentencing. In denying defendant's motion for a First Step Act reduction, the court erred in relying a drug-quantity figure that did not match the amount attributed to him at sentencing, and the matter is remanded for further consideration.
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