United States v. Jackson
Opinion Date: December 16, 2019
Judge: Jerry E. Smith
Areas of Law: Criminal Law
The abuse of discretion standard of review generally applies to rulings on motions to resentence under the First Step Act, because the Act gives the district court broad discretion in deciding whether to resentence. The Fifth Circuit held that, to the extent the district court's determination turns on "the meaning of a federal statute" such as the Act, the court's review is de novo. The court affirmed the district court's explanation, on limited remand, that it exercised its discretion not to resentence. In this case, the court held that although defendant was eligible for resentencing under the Act because he had a covered offense, the district court had broad discretion not to resentence him. The district court noted that defendant's life sentence still would have fallen within the appropriate statutory range were the Act applied, and it relied on his extensive criminal history and central role in the offense.
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