Watkins v. U.S. District Court for the Central District of Illinois
Ct. of Appeals dismissed as moot defendant’s appeal of Dist. Ct.’s order that denied defendant’s second section 2241 petition that challenged his mandatory life sentence on his drug distribution charge, where said sentence was based on three prior convictions for felony drug offense, and where defendant argued that two of his prior convictions did not qualify as predicate felony drug offenses under 21 USC 841(b)(A). While instant case was on appeal, plaintiff filed successful motion to reduce his sentence under section 404 of First Step Act of 2018 that resulted in new sentence to time served of approximately 15 years and imposition of reduced eight-year term of supervised release. Instant appeal is moot, since original life sentence was no longer applicable, and defendant received reduced sentence via his First Step Act claim. Moreover, fact that there was remote possibility that Dist. Ct. could sentence defendant to lower than 15-year term of incarceration that he received in his First Step Act claim did not require different result, where any further reduction in his term of incarceration would not actually shorten his prison time, even if Ct. of Appeals were to reach merits of instant appeal. Also, Ct. rejected defendant’s contention that decision on merits in instant appeal might produce reduced term of supervised release, since mere possibility that decision on instant appeal might influence Dist. Ct.‘s determination of supervised release on any remand was not enough to keep case alive, especially where Dist. Ct. had wide discretion on its own under section 3553(a) to impose new term of supervised release.