Summary
The Eighth Circuit held that non-retroactive changes in law—including the First Step Act's elimination of mandatory consecutive sentences under 18 U.S.C. § 924(c) and the Supreme Court's decision in *Mathis v. United States*—cannot constitute "extraordinary and compelling reasons" for a sentence reduction under 18 U.S.C. § 3582(c)(1)(A), either alone or in combination with other factors. The court affirmed the denial of compassionate release, reasoning that allowing such changes to justify release would circumvent Congress's intent to limit retroactivity and turn the statute into a discretionary parole system. The court also noted that the applicability of USSG §1B1.13 to defendant-filed motions remains unresolved but was unnecessary to decide.
Topics
Practice areas
Questions Presented
- Whether non-retroactive changes in law can constitute extraordinary and compelling reasons for a reduction of sentence under 18 U.S.C. § 3582(c)(1)(A).
- Whether the district court erred in refusing to consider a non-retroactive change in law as an extraordinary and compelling reason.
Holdings
- A non-retroactive change in law, whether offered alone or in combination with other factors, cannot contribute to a finding of 'extraordinary and compelling reasons' for a reduction in sentence under § 3582(c)(1)(A).
Key quotations
“Accordingly, we conclude that a non-retroactive change in law, whether offered alone or in combination with other factors, cannot contribute to a finding of 'extraordinary and compelling reasons' for a reduction in sentence under § 3582(c)(1)(A).” (at 7)
“Adding a legally impermissible ground to other insufficient factual considerations cannot justify a sentence reduction.” (at 7)
Factual background
Crandall was convicted in 1989 of bank robbery, conspiracy to commit armed bank robbery, using and carrying a firearm during a crime of violence, unlawful possession of a firearm as a convicted felon, and unlawful possession of an unregistered firearm. He was sentenced to 562 months' imprisonment, later reduced to 526 months. In 2020, he filed a motion for compassionate release, arguing that non-retroactive changes in law (the First Step Act's elimination of mandatory consecutive sentences for multiple § 924(c) convictions and the Mathis decision) would result in a significantly shorter sentence if he were sentenced today. The district court denied the motion, concluding that non-retroactive changes in law cannot constitute extraordinary and compelling reasons.
Procedural history
Crandall filed a motion for reduction of sentence based on extraordinary and compelling reasons. The district court denied the motion, ruling that non-retroactive changes in law cannot constitute extraordinary and compelling reasons. Crandall appealed.