Tydearain Smith was serving consecutive sentences for distributing crack cocaine and brandishing a firearm. After the Fair Sentencing Act’s retroactive changes, he asked whether he qualified for a reduction under the First Step Act and requested counsel. The district court treated his letter as a reduction motion and initially found him ineligible. On reconsideration, it ruled alternatively that he did not merit a reduction but denied his requests to brief that issue or reply to the government. The Eleventh Circuit held Smith eligible because the Fair Sentencing Act had lowered the statutory penalties for his crack offense, making it a covered offense under the First Step Act. The court also held that the district court could not deny relief on discretionary grounds without fair notice and an opportunity for Smith to present factual and legal arguments supporting a reduction. The lack of an opportunity to be heard on that material issue was not harmless. The court reversed and remanded for further proceedings, without deciding whether Smith should receive a reduced sentence.