U.S. v. Walker

Defendant was convicted of engaging in a continuing criminal enterprise and was sentenced to life in prison. Following passage of the First Step Act, defendant moved for a sentence reduction, arguing that his continuing criminal enterprise conviction qualified as a covered offense under the Act. The district court denied his motion and defendant appealed. The Seventh Circuit affirmed, finding that the offense did not qualify as a covered offense under the First Step Act, noting that an offense is only a covered offense if its statutory penalties were modified by the Fair Sentencing Act. (SYKES and KOLAR, concurring)