U.S. v. Hudson

Federal 7th Circuit Court
Criminal Court
Sentencing
Citation
Case Number: 
Nos. 19-2075 et al. Cons.
Decision Date: 
July 22, 2020
Federal District: 
N.D. Ill., W. Div.
Holding: 
Reversed and remanded

Dist. Ct. erred in denying three defendants’ motions to reduce their sentences under First Step Act. Record showed that all three defendants had covered drug-related offenses, and that Dist. Ct. held erroneous belief as to one defendant that it could not reduce his sentence for non-covered offense, where said offense had been grouped with other covered offenses to produce aggregate sentence. Moreover, with respect to two other defendants, Dist. Ct. held erroneous belief that First Step Act required sentencing guidelines to have changed as result of application of said Act for court to consider whether to reduce aggregate term of incarceration. While guideline range remained same for both defendants, both defendants were eligible for reduced sentences due to presence of covered offenses, and Dist. Ct. may consider all relevant factors in defendants’ request for reduced sentence, including different statutory penalties, previous and current Guidelines, post-sentencing conduct, and other factors regarding defendants’ history and characteristics.