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How the First Step Act Can Help People Serving Life Sentences for Drug Crimes


In 2018, Congress enacted the First Step Act, a series of reforms to the federal criminal justice system. One such reform was to change the mandatory minimum sentences for individuals previously convicted of certain drug offenses. In some cases, this means a person who received a mandatory life sentence can now ask for re-sentencing and possibly be released from prison altogether.

11th Circuit: Adding a Term of Supervised Release to a Reduction in Jail Time Is Permitted Under First Step Act

The U.S. 11th Circuit Court of Appeals recently addressed one aspect of the First Step Act. The case before the Court, United States v. Edwards, involved a defendant previously sentenced to life in prison for crack-related crimes. He sought modification of his sentence under the new law. A trial court granted this request and ordered the defendant to serve an eight-year term of supervised release. Before the 11th Circuit, the defendant argued the supervised release was impermissible under the First Step Act, which only permitted courts to “subtract from a sentence, not add to one.”

The appellate court first had to address a procedural issue. Separate from the First Step Act, there is another federal statute, 18 U.S.C. § 3582, which authorizes a court to “modify an imposed term of imprisonment.” The defendant here invoked both this statute and the First Step Act when seeking relief before the trial court.

The 11th Circuit explained that the First Step Act authorizes a judge to “impose a reduced sentence,” which is broader in scope than § 3582, which only applies to prison terms. In other words, the First Step Act covers multiple components of a criminal sentence, including any term of probation or supervised release, while § 3582 only deals with prison time.

The procedural question was whether the defendant was required to pursue First Step Act relief through § 3582 first. If so, then all the trial court could do was reduce the defendant’s prison sentence; it could not also impose a new term of supervised release. Ultimately, the 11th Circuit concluded that the First Step Act was “self-contained and self-executing,” meaning the court did not have to rely on § 3582 in making its decision.

Turning to the merits, the 11th Circuit said the First Step Act does not prevent a court from reducing a defendant’s prison term and also imposing a new term of supervised release. So long as the “overall sentence” is reduced, the law is satisfied. And given the defendant was previously sentenced to life in prison, the reduction in jail time–from life to approximately 21 years in this case, including time already served–followed by a period supervised release clearly qualified as an overall reduction in sentence.

Contact Florida Criminal Defense Attorney Jose Baez Today

Even with the First Step Act, the penalties for many drug crimes remain harsh and unforgiving. So if you are facing such charges it is imperative that you work with an experienced Orlando drug crimes lawyer who will aggressively advocate for your interests. Contact the Baez Law Firm to speak with a member of our legal team today.


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