First Circuit - First Step Act of 2018

United States v. Cruz-Rivera, 954 F.3d 410 (1st Cir. 2020). Section 403 of the First Step Act prohibits stacking sentences for contemporaneous convictions of § 924(c) as if they were subsequent convictions, but this rule does not apply to cases on appeal when the Act was passed.

United States v. Smith, 954 F.3d 446 (1st Cir. 2020). A defendant convicted of distributing less than two grams of crack cocaine, in violation of 21 U.S.C. §§ 841(a) and (b)(1)(C), is eligible for relief under § 404(b) of the First Step Act.

United States v. Concepcion, 991 F.3d 279 (1st Cir. 2021). Section 404 of the First Step Act, which permits a court to reduce a sentence for a covered offense, does not entitle an eligible defendant to a plenary resentencing.

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