UNITED STATES v. WILLIAMS (2021)

United States Court of Appeals, Eighth Circuit.2021-01-04No. No. 19-3680

Summary · law.co

Holding. The district court's denial of Williams's First Step Act sentence-reduction motion was affirmed.

Andre Williams sought a sentence reduction under the First Step Act following his 2008 drug conspiracy conviction. The district court had previously reduced his sentence in 2014 under sentencing guidelines amendments, but declined to grant further relief under the First Step Act. Williams appealed, arguing the district court either misunderstood its authority or failed to properly review his motion.

The appellate court concluded that Williams was eligible for First Step Act relief based on his statute of conviction. However, the court found no abuse of discretion in the district court's decision to deny the reduction. The district court's statement that it would decline to grant relief was a clear exercise of discretion, and the court had adequately considered the relevant sentencing factors and Williams's arguments before reaching its decision.

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

Key issues

Eligibility for First Step Act sentencing reduction based on statute of conviction
Whether district court abused discretion in denying sentence reduction for eligible defendant
Scope of district court's authority and discretion under First Step Act § 404
Whether district court provided complete review of defendant's sentencing motion

Procedural posture

Williams appealed the district court's denial of his motion for a sentence reduction under the First Step Act.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

[Unpublished]

Andre Williams moved for a reduced sentence under the First Step Act. The district court

declined to grant that reduction. We affirm.

In 2008, a jury convicted Williams of conspiring to manufacture, distribute, or possess with intent to distribute fifty grams or more of cocaine base, conspiring to open and maintain a house for manufacturing and distributing cocaine base, opening and maintaining such a house, and distributing cocaine base. See 21 U.S.C. §§ 841(a)(1), 841(b)(1)(A), 841(b)(1)(C), 846, and 856(a)(1). The district court sentenced Williams to 292 months of imprisonment for the conspiracy count and 240 months on each of the other counts, all to be served concurrently. In 2014, the district court reduced his sentence to 235 months under United States Sentencing Guidelines’ Amendment 782. See 18 U.S.C. § 3582(c)(2). After the First Step Act passed in 2018, Williams moved for another sentence reduction. See First Step Act of 2018, Pub. L. No. 115-391, § 404, 132 Stat. 5194.

The district court denied that motion, stating: “the First Step Acts grant of retroactive relief for those sentenced prior to the enactment of the Fair Sentencing Act ․ affords the defendant no relief․ The court has reviewed the entire record and would decline to grant relief if it were available to this defendant.” Williams now appeals.

We review the legal question of Williamss sentence-reduction eligibility de novo and the denial of that reduction for abuse of discretion. United States v. McDonald, 944 F.3d 769, 771 (8th Cir. 2019). In conducting the abuse of discretion review, a significant procedural error occurs if the district court failed “to understand the scope of its authority and discretion at sentencing.” United States v. Moody, 930 F.3d 991, 993 (8th Cir. 2019) (quoting United States v. Tabor, 531 F.3d 688, 692 (8th Cir. 2008)). An error was harmless if it did not affect the sentencing conclusion. Id.

The First Step Act sentencing-reduction analysis involves two steps. First, a district court must decide if the defendant is eligible for a reduction under § 404. See McDonald, 944 F.3d at 772. Second, for an eligible defendant, the district court has discretion to choose whether to grant a reduction. Id.

After our recent rulings clarifying that we base eligibility determinations on the statute of conviction, rather than the defendants conduct, the government conceded Williamss § 404 eligibility. See United States v. Howard, 962 F.3d 1013, 1014 (8th Cir. 2020); United States v. Banks, 960 F.3d 982, 984 (8th Cir. 2020) (quoting McDonald, 944 F.3d at 772). Accordingly, we conclude that Williams is eligible for relief because his statute of conviction, 21 U.S.C. § 841, is a “covered offense” under § 404(a). See McDonald, 944 F.3d at 772.

In light of his eligibility for relief, Williams contends that the district court abused its discretion by misapprehending the broad scope of its authority. We disagree.

We are not inclined to read the district courts order as saying that Williams was ineligible for relief under § 404. Instead, the district court stated it “would decline to grant relief” to Williams “if it were available.” But even if the district court had erred regarding Williamss eligibility, the courts “plain statement” that it would not exercise its discretion to reduce Williamss sentence under the First Step Act is enough to “close[ ] the matter.” Howard, 962 F.3d at 1015 (affirming the denial of a sentencing-reduction motion under similar circumstances); see United States v. Hoskins, 973 F.3d 918, 920–21 (8th Cir. 2020) (same).

Williams also argues the district court abused its discretion by violating his right to a “complete review” of his motion. A complete review occurs when a “district court consider[s] petitioners arguments in the motion and had a reasoned basis for its decision.” United States v. Moore, 963 F.3d 725, 728 (8th Cir. 2020) (cleaned up) (quoting United States v. Williams, 943 F.3d 841, 844 (8th Cir. 2019)). Here, the district court stated that the § 3553(a) factors and Williamss Guidelines range drove the sentence. Because we presume the district court considered a defendants arguments before making a sentencing determination, United States v. Timberlake, 679 F.3d 1008, 1012 (8th Cir. 2012), we hold that the district court conducted a “complete review” of Williamss motion.

As the original sentencing court, the district court was “uniquely positioned to consider the many factors necessary in exercising its ultimate discretion,” and it specifically addressed its First-Step-Act discretion. Howard, 962 F.3d at 1015. Thus, we are satisfied that the district court did not abuse its substantial discretion in denying Williamss requested reduction.

The district courts judgment is affirmed.

FOOTNOTES

. The Honorable John A. Jarvey, Chief Judge, United States District Court for the Southern District of Iowa.

PER CURIAM.