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Keywords

defendantappealmotionlease
defendantappealmotionleasepiracy

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United States v. Chen, 48 F.4th 1092, 2022 Daily Journal D.A.R. 9862

Facts

Howard Chen was convicted in 2007 of multiple drug-related offenses and possession of a firearm in furtherance of a drug trafficking crime. He was sentenced to a total of 408 months' imprisonment, which included a stacked 300-month sentence for a second § 924(c) conviction. In 2018, the First Step Act changed the law regarding stacked sentences, but the changes were made non-retroactive. In 2020, Chen filed a motion for compassionate release, arguing that the new law constituted extraordinary and compelling reasons for a sentence reduction.

Chen's case arises out of a conspiracy to traffic large quantities of MDMA between November 2006 and May 2007. After Chen negotiated to sell MDMA pills to an informant for the DEA, local law enforcement agents stopped Chen's car and found 831 grams of MDMA and a firearm.

Issue

Whether a district court may consider the First Step Act's non-retroactive changes to sentencing law when evaluating a motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A).

Whether a district court may consider the First Step Act's non-retroactive changes to sentencing law when evaluating a motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A).

Rule

A district court may consider any extraordinary and compelling reason for release that a defendant might raise, including non-retroactive changes in sentencing law, when determining whether extraordinary and compelling reasons exist for a sentence reduction under 18 U.S.C. § 3582(c)(1)(A).

A district court may consider any extraordinary and compelling reason for release that a defendant might raise, including non-retroactive changes in sentencing law, when determining whether extraordinary and compelling reasons exist for a sentence reduction under 18 U.S.C. § 3582(c)(1)(A).

Analysis

The Court of Appeals determined that the district court erred by not considering the First Step Act's non-retroactive changes to stacked sentencing when evaluating Chen's motion for compassionate release. The court emphasized that there is no explicit prohibition against considering such changes and that the determination of extraordinary and compelling reasons lies within the district court's discretion. The court also noted that allowing consideration of these changes does not conflict with Congress's intent regarding non-retroactivity.

We are not persuaded by the reasoning in Andrews and Thacker that forbids district courts from considering § 403(a)'s changes in the extraordinary and compelling context, but nevertheless permits those same changes to be considered in the § 3553(a) context.

Conclusion

The Court of Appeals vacated the district court's decision and remanded the case for reassessment of Chen's motion for compassionate release, allowing for consideration of the First Step Act's non-retroactive changes in sentencing law.

The district court erred when it declined to consider § 403(a)'s non-retroactive changes to § 924(c) stacked sentencing when evaluating Chen's motion for compassionate release.

Who won?

Howard Chen prevailed in the appeal because the Court of Appeals found that the district court had erred in its legal reasoning by not considering the First Step Act's changes to sentencing law.

Howard Chen prevailed in the appeal because the Court of Appeals found that the district court had erred in its legal reasoning by not considering the First Step Act's changes to sentencing law.

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