United States v. Caver, No. 21-3753 (6th Cir. 2024)
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Calvin Caver was sentenced to life imprisonment for conspiring to distribute more than 50 grams of crack cocaine, having committed three prior felony drug offenses. The Fair Sentencing Act of 2010 later increased the amount of crack cocaine required to trigger a life sentence to 280 grams. The First Step Act of 2018 allowed defendants like Caver to seek retroactive relief as if they had committed their crimes after the Fair Sentencing Act. Caver sought a reduced sentence under the First Step Act, but the district court held that the Act gave it no discretion to grant him relief. The court reasoned that Caver's jury had found that his drug crime involved at least 500 grams of crack cocaine, an amount that still exceeded the 280 grams required to trigger a mandatory life sentence after the Fair Sentencing Act.
The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court clarified that if the Fair Sentencing Act's changes would still trigger the same mandatory-minimum sentence that a district court originally imposed, a district court lacks discretion to reduce the defendant’s sentence below that minimum under the First Step Act. The court also noted that the First Step Act allows a court to impose a reduced sentence as if the Fair Sentencing Act were in effect at the time the covered offense was committed. The court concluded that no plausible reading of the First Step Act or the caselaw interpreting it permitted the district court to sentence Caver below the mandatory-minimum term that he faced under the Fair Sentencing Act.
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