Defendant Sentenced After Fair Sentencing Act Was Enacted Not Eligible for Reduced Sentence

US v. Goodwin: In 2009, before the Fair Sentencing Act was passed, Goodwin was charged with conspiring to distribute powder and crack cocaine. Prior to his sentencing, the Fair Sentencing Act was passed and the Supreme Court decided Dorsey, in which the Court held that the Act applied to anyone sentenced after the Act went into effect. Goodwin eventually pleaded guilty to the conspiracy and admitted that he distributed at least five kilograms of powder cocaine. He was sentenced to a 240-month mandatory minimum, with some credit for time served on a concurrent state sentence, enhanced based on prior convictions. The Fair Sentencing Act wasn’t mentioned at sentencing.

In 2020, Goodwin filed for a reduced sentence under the First Step Act, arguing both that his conviction was for a “covered offense” making him eligible for a reduction and that the district court should take into consideration that the Fair Sentencing Act’s changes to the consideration of prior offenses meant he was no longer subject to the 240-month mandatory minimum. The district court “appeared to agree with Goodwin” that he was eligible, but “agreed with the government” that it could not reduce his sentence because the powder cocaine involved still triggered the same mandatory minimum sentence.