US v. Lancaster: In 2009, Lancaster pleaded guilty to a conspiracy involving more than 50 grams of crack cocaine, subjecting him to a mandatory minimum sentence of 120 months in prison. He was classified as a career offender at sentencing and ultimately received a sentence of 180 months in prison. In 2020, he filed a motion under the First Step Act’s retroactive application of the Fair Sentencing Act, seeking a sentence of time served, based on the argument that he was no longer a career offender. The district court denied the motion in a brief, one-paragraph order, concluding that it would have imposed the same sentence had the Fair Sentencing Act been in effect.
On appeal, the Fourth Circuit reversed the denial of relief under the First Step Act. While the district court’s ultimate conclusion that no relief should be granted might end up being correct, it did not properly analyze Lancaster’s request. Critically, the district court failed to recalculate the Guideline range in light of “intervening case law.” At the time of Lancaster’s conviction his offense of conviction – conspiracy – was a “controlled substance offense,” but that is no longer the case. Remand was required for the district court to perform that analysis and, ultimately, determine whether relief was appropriate.
Judge Wilkinson concurred in the result, agreeing that it was required by prior Fourth Circuit precedent. However, he noted that “to say these holdings exacerbate a circuit split greatly understates the matter” and that the issue “is an altogether serious one in sentencing, and I respectfully request that the sooner the Supreme Court resolves the fractured views concerning it, the better of we all will be.”
Congrats to the Defender office in Eastern North Carolina on the win!
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