United States v. Kojak Batiste

Summary

The Fifth Circuit affirmed the denial of a sentence reduction under Section 404 of the First Step Act for a crack cocaine conviction, holding that the district court did not abuse its discretion in re-imposing a 262-month sentence where the career-offender guidelines range remained unchanged and the court considered the § 3553(a) factors and post-sentencing conduct. The court reaffirmed that _Hegwood_ limits resentencing to changes mandated by the Fair Sentencing Act—excluding alterations to career-offender status—and that district courts are not required but may consider post-sentencing conduct or § 3553(a) factors. However, because the district court’s order did not address the defendant’s request for a reduction in his supervised-release term from 10 years to the current 8-year minimum, the case was remanded for consideration of that issue.

Holdings

1. The district court did not misinterpret Hegwood; it properly exercised its discretion and considered the § 3553(a) factors, and no abuse of discretion occurred.
2. The district court's explanation was adequate regarding the imprisonment term, but it did not address the supervised release request, so that part is remanded.
3. Substantive reasonableness review does not apply in First Step Act proceedings; the district court did not abuse its discretion.
4. Foreclosed by Hegwood; the district court correctly applied the unchanged career offender status.

Questions Presented

1. Whether the district court misinterpreted Hegwood as precluding consideration of § 3553(a) factors or preventing a downward variance from the unchanged guidelines range.
2. Whether the district court provided an adequate explanation for its decision.
3. Whether the re-imposed 262-month sentence was substantively unreasonable.
4. Whether the district court should have recalculated the guidelines range based on current non-career offender status (foreclosed by Hegwood).

Disposition

affirmed