Terry v. United States, 141 S. Ct. 1858 (2021). A defendant convicted of a crack cocaine offense that does not trigger a mandatory minimum, under 21 U.S.C. § 841(b)(1)(C) does not have a “covered offense” for purposes of section 404 of the First Step Act and is not entitled to a sentencing reduction. Section 2(a) of the Fair Sentencing Act of 2010 only modified the mandatory-minimum penalties under 21 U.S.C. §§ 841(b)(1)(A) and (B).