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Thirty-Year Drug Sentence Must Be Reduced Under First Step Act

April 27, 2021, 4:05 PM

A drug dealer is entitled to have his 30-year sentence recalculated under the First Step Act using the now applicable 20-year statutory maximum as the basis, the Fourth Circuit said.

Chuck Collington’s new sentence must also be subject to a reasonableness review, the opinion by Judge Henry F. Floyd said, putting the court in the middle of a circuit split on the issue. That holding aligned with the Sixth and D.C. circuits, while the First, Second, Fifth, Ninth, and Tenth circuits generally look at whether the district court abused its discretion calculating a First Step Act sentence.

In 2009, Collington ...