United States v. Rogers, No. 23-1461 (8th Cir. 2024)
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In this case heard before the United States Court of Appeals for the Eighth Circuit, the appellant, Dewanis Rogers, sought a reduced sentence under the First Step Act of 2018. Rogers had been found guilty in 2008 of conspiracy to distribute 50 grams or more of cocaine within 1,000 feet of a protected location, following two or more prior felony drug convictions. He received a mandatory sentence of life imprisonment, as prescribed by statute. In 2022, Rogers requested that his sentence be reduced under the provisions of the First Step Act. The district court denied this motion, determining that Rogers was ineligible for relief under the Act. Rogers appealed this decision, disputing his ineligibility.
Upon review, the United States Court of Appeals for the Eighth Circuit held that even if Rogers was eligible for relief under the First Step Act, the district court could not have lawfully reduced his sentence due to the mandatory term of imprisonment prescribed by statute. The court explained that Congress had not expressly repealed the mandatory punishment for Rogers’s offense in the First Step Act, and that the change in law cited by Rogers did not appear in the sections of the Fair Sentencing Act of 2010 made retroactive by the First Step Act. Therefore, the court affirmed the district court's decision.
Court Description: [Colloton, Author, with Wollman and Benton, Circuit Judges] Criminal case - Sentencing. The district court did not err in declining to impose a reduced sentence under the First Step Act as it could not lawfully reduce the sentence because defendant was still subject to the mandatory term of life imprisonment that applied under 21 U.S.C. Sec. 841(b)(1)(A) at the time of his offense.
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