Sentence Reduction-First Step Act of 2018

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7^th Circuit Court of Appeals

Case Name: United States of America v. Adam Williams, Jr.

Case No.: 23-2313

Officials: Easterbrook, Wood, and Jackson-Akiwumi, Circuit Judges.

Focus: Sentence Reduction-First Step Act of 2018

The Seventh Circuit revisited a case involving Adam Tyrale Williams Jr.’s persistent efforts to reduce his sentences for crack-cocaine offenses. Williams had been convicted in 2001 of various drug-related crimes, and over the years, he had sought sentence reductions based on retroactive guideline amendments and, most recently, the First Step Act of 2018. Although the Northern District of Indiana initially denied Williams’s latest application for sentence reduction, the appellate court overturned this decision because the district court had failed to calculate the revised statutory sentencing ranges applicable to Williams’s convictions. Upon remand, Williams underscored additional changes to his circumstances and confinement conditions that had occurred since the original decision was overturned. However, the district court once again denied Williams’s request shortly after receiving the updated motion. The appellate court determined that the district court’s reliance on its previous rationale and its failure to adequately justify its decision amounted to an abuse of discretion. Consequently, the appellate court vacated the judgment and remanded the case for further proceedings, emphasizing the need for a more thorough explanation from the district court, particularly in light of the evolving legal landscape and factual developments pertinent to the case.

Vacated and remanded.

Decided 02/20/24

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