On Thursday, the U.S. Supreme Court issued a ruling that will impact first-time offenders and convicted bank robbers who used firearms during the commission of their crimes and were sentenced to long prison terms based on pre-First Step Act mandatory minimums. The decision clarifies whether those whose sentences were vacated after the First Step Act was enacted are entitled to the more lenient sentencing provisions established by the reform law.
Key Ruling on the First Step Act
The First Step Act, signed into law in 2018, brought significant criminal justice reforms, including reducing mandatory minimum sentences for certain offenses. Under the law, first-time offenders sentenced under federal mandatory minimum laws for crimes committed with a firearm became eligible for leniency. However, the law only applied to cases that were pending when it passed, leaving open the question of whether the leniency should apply retroactively to those whose sentences had been vacated after the First Step Act’s enactment.
Section 403 of the First Step Act amended federal law to eliminate the additional 25-year mandatory minimum sentence that was previously required for certain firearm offenses. Justice Ketanji Brown Jackson, writing for the majority, concluded that when a sentence is vacated, it is as if no sentence has been imposed, allowing the defendant to benefit from the more lenient penalties under the First Step Act.
“We hold that, under that circumstance, a sentence ‘has not been imposed’ for purposes of §403(b),” Jackson wrote, emphasizing that the Act’s reduced mandatory minimum penalties should apply.
The Dissent: Alito and Other Justices Disagree
Justice Samuel Alito led the dissent, joined by Justices Clarence Thomas, Brett Kavanaugh, and Amy Coney Barrett. Alito argued that the sentences of the petitioners, which were imposed before the First Step Act’s enactment, should not be subject to the new law’s leniency simply because they were later vacated. He criticized the majority opinion for “disfiguring the Act” and suggested that it was influenced by a desire for sentencing reform rather than a faithful interpretation of the law’s text.
“The Court’s interpretation… unspools the Act’s carefully wound retroactivity command to mean that any defendant whose sentence is vacated at any time and for any reason may claim the benefit of the Act’s reduced mandatory minimum,” Alito wrote, expressing concern over what he saw as an overly broad interpretation of the Act’s retroactivity.
The Core Issue: Retroactive Application of Sentencing Reduction
The central question before the Court was whether the First Step Act’s sentencing reductions should apply when a defendant’s original sentence, imposed before the Act, is vacated and they are resentenced after the Act’s passage. The petitioners in the cases of Hewitt v. United States and Duffey v. United States argued that their sentences should be recalculated based on the reforms in the First Step Act, as their cases were effectively in the post-Act legal framework after their sentences were vacated.
Justice Jackson, in her majority opinion, stressed that the goal of the First Step Act was to reform the harsh sentencing practices that were widely criticized, particularly the “stacking” of mandatory minimums that resulted in extremely long sentences. She argued that the intent of Congress was clear in seeking to provide relief from these draconian practices, and thus the petitioners’ requests for relief were justified.
Legal Implications
This ruling clarifies that defendants whose sentences were vacated after the First Step Act was enacted should benefit from its reduced mandatory minimum sentences, aligning with the broader goals of sentencing reform. The decision is significant for individuals who were sentenced under pre-First Step Act laws and whose cases were later vacated, as it ensures they will not be subject to the harsher penalties that were once mandatory.
However, the decision also underscores the divide within the Court, with the dissenting justices expressing concern that the majority was overstepping in its interpretation of the law.
The U.S. Supreme Court’s ruling brings clarity to the issue of how the First Step Act applies to cases where sentences have been vacated. The majority opinion, supported by Justices Jackson, Sotomayor, Kagan, and Gorsuch, emphasizes Congress’s intent to reduce harsh mandatory minimums. Meanwhile, the dissent led by Justice Alito warns against an overly broad application of retroactive relief. The decision will have a lasting impact on the application of criminal sentencing reforms under the First Step Act, particularly for those whose sentences were previously vacated.
