U.S. v. Black

Defendant appealed from the district court’s denial of his motion for sentence reduction in which defendant argued that the anti-stacking amendment contained in the First Step Act constituted an extraordinary and compelling reason to reduce his 40-year sentence, 30 years of which came from stacked convictions. The Seventh Circuit affirmed, following prior precedent in which the court held that the First Step Act’s anti-stacking amendment did not constitute an extraordinary and compelling reason for compassionate release and that a policy statement by the U.S. Sentencing Commission to the contrary exceeded the commission’s statutory authority. (RIPPLE, separately concurring and HAMILTON, dissenting)