Concepcion v. United States

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Sentencing
  • Date Filed: June 27, 2022
  • Case #: 20-1650
  • Judge(s)/Court Below: SOTOMAYOR, J., delivered the opinion of the Court, in which THOMAS, BREYER, KAGAN, and GORSUCH, JJ., joined. KAVANAUGH, J., filed a dissenting opinion, in which ROBERTS, C. J., and ALITO and BARRETT, JJ., joined.
  • Full Text Opinion

The First Step Act allows a district court to consider intervening changes of law or fact when exercising their discretion to modify a sentence.

Petitioner was sentenced as a “career offender” to a 262-to-327-month prison sentence for distributing crack cocaine. Petitioner filed a pro se motion for sentence reduction under the First Step Act, arguing his eligibility for relief as the Fair Sentencing Act modified the statutory penalties of his conviction lowering his guideline range of time served. The District Court declined to consider Petitioner’s arguments, believing they had no discretion and the Court of Appeals affirmed. The Court granted certiorari to resolve whether a district court may consider other intervening changes of law or fact when adjudicating a motion under the First Step Act. This Court held the First Step Act allows a district court to consider intervening changes of law or fact in exercising their discretion to reduce a sentence pursuant to the First Step Act. The Court reasoned only the Constitution or Congress can restrain a district court’s discretion by limiting the scope of information a district court may consider in modifying a sentence and the First Step Act does not restrain a district court’s discretion. Therefore, a district court has discretion of First Step Act motions to consider intervening changes of law or fact. REVERSED AND REMANDED.

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