US v. McDonald: This appeal involves three cases where defendants sought relief under the First Step Act's retroactive application of the Fair Sentencing Act of 2010. In each case, the defendants were convicted of offenses with life maximum statutory sentences that, with the application of the Fair Sentencing Act, now have 40-year maximums. All defendants received original sentences that were below the new statutory maximum. The district court found them all eligible for relief, but provided limited reductions - reducing only the terms of supervised release for all defendants. For one defendant, who was already on supervised release, the court did not similarly reduce his supervised release term on another count of conviction, meaning he got no relief at all. In all three cases the only thing the district court did to explain its sentence was fill out an Administrative Office form, checking boxes that the motion was "granted" and the supervised release term revoked.
On appeal, the Fourth Circuit vacated all these sentences. The court adopted the presumption from retroactive Guideline cases that the district court considered all relevant factors in decided a motion seeking a reduced sentence. However, that presumption can be rebutted and is in cases like these where the defendants present sufficient evidence of post-sentencing rehabilitation. In such cases, the district court must provide an individualized explanation for its resolution of the defendant's motion to reduce his sentence. In these cases, "it is not at all clear that the district court considered or gave any weight to [the defendants] post-sentencing conduct."
Congrats to the defender office in NDWV on the wins!