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United Statesv.Alfonso Allen

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.19-10758
DecidedJune 16, 2020
Reporter530 U.S. 466
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
CriminalCriminal LawCriminal ProcedureSentencingSentencing GuidelinesStatutory InterpretationVacaturRemand
Case Summary

Steven Jones, Alfonso Allen, Warren Jackson, and Thomas Johnson sought reduced sentences under the First Step Act of 2018, which made lower crack-cocaine penalties retroactive for eligible defendants. The Eleventh Circuit affirmed denial of Jones’s and Jackson’s motions. It vacated the orders denying Allen’s and Johnson’s motions because the records did not make clear whether the district courts understood their authority to reduce sentences below revised guideline ranges. The court held that the First Step Act did not bar a reduction below the revised range, even when a sentence had already been reduced or commuted. It remanded for the district courts to clarify whether they exercised that discretion or mistakenly believed they lacked it. The opinion consolidated four appeals arising from the same statutory question.

Opinion

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