UNITED STATES v. WILLIAMS (2021)

United States Court of Appeals, Ninth Circuit.2021-02-22No. No. 20-50077

Summary · law.co

Holding. The court affirmed the district court's denial of Williams's habeas petition, finding him ineligible for First Step Act relief because his sentence was imposed before the Act's enactment, and rejecting his alternative legal theories.

George Williams, a federal prisoner serving a life sentence, appealed seeking a sentence reduction under the First Step Act of 2018. Williams argued he qualified for relief under section 401 of that statute, which allows sentence reductions for certain drug offenses. However, the statute's eligibility requirement limits relief to defendants whose sentences had not yet been imposed when the Act became law. Since Williams received his sentence in 2006—well before the First Step Act's 2018 enactment—he did not meet this temporal requirement.

The court rejected Williams's alternative arguments as well. He contended that the General Savings Statute could allow application of the new sentencing rules to his case, but that statute did not provide the pathway he sought. Williams also claimed the non-retroactive application violated equal protection principles under the Fifth Amendment, but the court found this argument was already foreclosed by established precedent.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Temporal eligibility requirement for First Step Act sentence reductions
Retroactive versus non-retroactive application of criminal sentencing statutes
Whether the General Savings Statute permits application of new sentencing regimes to prior sentences
Fifth Amendment equal protection challenge to non-retroactive statutory application

Procedural posture

A federal prisoner appealed pro se from a district court order denying his habeas corpus petition seeking sentence reduction under the First Step Act.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

MEMORANDUM **

Federal prisoner George Williams appeals pro se from the district courts order denying his “Petition for Writ of Habeas Corpus Pursuant to 28 U.S.C. § 2241 or for Any Relief Submitted Pro Se,” in which he sought a reduction in his life sentence by retroactive application of the First Step Act of 2018. We have jurisdiction under 28 U.S.C. § 1291, and we affirm.

Williams contends that he is eligible for a sentence reduction under section 401 of the First Step Act. However, section 401 applies to pre-Act conduct only if the defendants sentence had not yet been imposed as of the date of the Acts enactment. See First Step Act § 401(c); United States v. Asuncion, 974 F.3d 929, 934 (9th Cir. 2020). It is undisputed that Williamss sentence was imposed in 2006 and became final in 2009; the district court therefore did not err by determining Williams was ineligible for relief. See Asuncion, 974 F.3d at 934. Nor did the district court err by determining the General Savings Statute, 1 U.S.C. § 109, also foreclosed applying the new sentencing regime to Williams. See United States v. Baptist, 646 F.3d 1225, 1227 (9th Cir. 2011). To the extent Williams contends that non-retroactive application of section 401 violates the Equal Protection Clause of the Fifth Amendment, that argument is foreclosed. See id. at 1228-29.

Williamss motion requesting that his opening brief be treated as his reply is granted.

AFFIRMED.