U.S. v. Williams

Dist. Ct. committed plain error in denying defendant’s motion to reduce his 360-month sentence on certain crack-cocaine offenses pursuant to First Step Act. Defendant originally had been given life sentence on said offenses, which was reduced in 2014 to 360-month sentence based on retroactive sentencing guideline amendments. In 2019, defendant filed instant request for reduced sentence under section 404 of First Step Act, and Dist. Ct. denied said request, after finding that reprehensibility of defendant’s offenses outweighed defendant’s youth at time of offenses, lack of significant criminal history and near perfect disciplinary record in prison. However, remand was required for reconsideration of defendant’s request, where Dist. Ct. failed to calculate new statutory ranges for defendant’s three offenses, which deprived defendant of benefit of any anchoring effect that new statutory ranges could have had on Dist. Ct.’s decision.