United States v. Robinson, No. 20-1947 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit reversed the district court's denial of defendant's motion for a sentence reduction under the First Step Act of 2018, concluding that the district court erred in determining that defendant remains subject to a mandatory life sentence. The court explained that defendant's offense of conviction—not the underlying drug quantity—determines his applicable statutory sentencing range. In this case, the district court erred in determining that defendant remained subject to a mandatory life sentence based on defendant's conduct rather than the offense of conviction, and the district court erroneously concluded that relief was categorically unavailable because of the drug quantity. The court remanded for the district court to determine whether to exercise its discretion in imposing a reduced sentence.
Court Description: [Per Curiam - Before Gruender, Kelly, and Grasz, Circuit Judges] Criminal case - Sentencing - First Step Act. The district court erred in determining that defendant remained subject to a mandatory life sentence because it looked at conduct rather than the offense of conviction; because the district court erroneously concluded that relief was categorically unavailable because of the drug quantity, the matter is remanded to permit the court to decide whether, in the exercise of its discretion, it would impose a reduced sentence. Judge Grasz, dissenting.
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