United States v. Milton, No. 20-1916 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of defendant's motion for a sentence reduction under the First Step Act. The court has clarified that, while the district court may consider the 18 U.S.C. 3553(a) factors in exercising its First Step Act discretion, the Act does not require it to do so. The court concluded that the district court did not err in considering the impact on the Act of defendant's guidelines range. In this case, the entire sentencing record, including the prior motions for sentence reduction under guidelines amendments, supports the finding that defendant was responsible for 5.268 kilograms of crack cocaine and therefore the bottom of the amended range under the Act would remain 360 months. Finally, the court concluded that there was no error in failing to consider defendant's request for compassionate release where he failed to exhaust his administrative remedies.
Court Description: [Loken, Author, with Wollman and Stras, Circuit Judges] Criminal case - Sentencing - First Step Act. The district court did not abuse its discretion by denying Milton's motion for a First Step Act sentence reduction; the district court may consider the 3553(a) factors in deciding the motion, but it is not required to; the entire sentencing record, including prior motions for sentence reduction, supports the finding that Milton was responsible for 5.2 kilos of crack and that the bottom of his amended range under the First Step Act would remain at 360 months; the district court did not err in refusing to consider Milton's request for compassionate release where he had not exhausted his administrative remedies with the BOP.
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