Bloomberg Law
March 10, 2023, 7:52 PM

Inmate Serving Time for Manslaughter Not Helped by New Drug Law

Bernie Pazanowski
Bernie Pazanowski

The First Step Act doesn’t apply to an inmate who’s already completed his sentence, the US Court of Appeals for the Third Circuit said Friday.

Elroy Brow, who had already finished serving 30 years for a drug conviction, must stay in prison to finish the consecutive 10-year sentence for an unrelated manslaughter conviction, the court said.

The First Step Act made retroactive the provisions of the Fair Sentencing Act reducing the disparity between sentences for powder cocaine and those for crack cocaine. The First Step Act says that courts may impose a reduced sentence as if specific provisions of the ...