United States v. Goodwin, No. 22-5845 (6th Cir. 2023)
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In five 2008 transactions, Goodwin distributed a total of 71.9 grams of crack cocaine to a confidential informant. He pleaded guilty to a conspiracy to distribute at least 50 grams of crack cocaine, 21 U.S.C. 846. Goodwin had a prior “felony drug offense,” 21 U.S.C. 841(b)(1)(A), and faced a statutory minimum 20-year sentence. The district court found that two of his prior offenses made him a “career offender,” calculated his guidelines range as 262-327 months, and imposed a 262-month sentence. After Goodwin’s sentencing, the 2010 Fair Sentencing Act increased the amount of crack cocaine necessary to subject Goodwin to his 20-year minimum sentence from 50 to 280 grams; the 2018 First Step Act made that change retroactive. Goodwin moved for a reduced sentence under the Act. In 2020, before that motion was resolved, the Bureau of Prisons allowed Goodwin to serve the remainder of his sentence in home confinement because of the COVID-19 pandemic (CARES Act, 134 Stat. 281, 516).
Two years later, the district court denied Goodwin’s motion for a reduced sentence primarily because his guidelines range remained the same even after the statutory changes. The Sixth Circuit affirmed, rejecting arguments that the district court committed a procedural error by denying relief in a cursory order and committed a substantive error because Goodwin's rehabilitation efforts (combined with other legal changes) required the court to issue a below-guidelines sentence.
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