Jacques Hernes Telcy v. United States, 20 F.4th 735

Telcy was convicted of drug and firearm offenses and received a life sentence on Count 1 due to an Armed Career Criminal Act (ACCA) enhancement; his direct appeal and initial §2255 petition were unsuccessful.
The First Step Act (2018) made Fair Sentencing Act penalties retroactive for covered offenses; Telcy moved under §404(b) for a sentence reduction.
The district court granted a reduction (life → 235 months) without a plenary resentencing, hearing, or re-adjudication of factual findings.
Telcy then filed a pro se §2255 petition challenging the ACCA enhancement, arguing the First Step Act reduction produced a "new judgment" (Magwood) so he need not obtain appellate authorization for a second §2255.
The district court dismissed the §2255 as second or successive for lack of Eleventh Circuit authorization; the Eleventh Circuit affirmed, holding a First Step Act reduction is not a "new judgment."

Issue	Telcy's Argument	Government's Argument	Held
Whether a sentence reduction under the First Step Act §404(b) is a “new judgment” that resets AEDPA’s second-or-successive bar	Telcy: Magwood and similar authorities treat the post-reduction sentence as a new judgment permitting a new, first §2255	Gov: §404(b) reductions are discretionary §3582 sentence modifications, not plenary resentencings; they do not create a new judgment	Reduction is not a new judgment; Telcy’s §2255 was second or successive and required prior Eleventh Circuit authorization

Magwood v. Patterson, 561 U.S. 320 (2010) (a habeas petition challenging an intervening full resentencing is not "second or successive")
Dillon v. United States, 560 U.S. 817 (2010) (§3582 sentence reductions are not plenary resentencings for Sixth Amendment purposes)
Armstrong v. United States, 986 F.3d 1345 (11th Cir. 2021) (§3582(c)(2) reductions do not create new judgments under AEDPA)
Insignares v. Sec'y, Fla. Dep't of Corr., 755 F.3d 1273 (11th Cir. 2014) (Florida Rule 3.800 correction that produced a new entered sentence constituted a new judgment)
Patterson v. Sec'y, Fla. Dep't of Corr., 849 F.3d 1321 (11th Cir. 2017) (en banc) (distinguishing Insignares where a sentence modification did not produce a new judgment)
United States v. Jones, 962 F.3d 1290 (11th Cir. 2020) (First Step Act "as-if" requirement binds district courts to prior drug-quantity findings)
United States v. Stevens, 997 F.3d 1307 (11th Cir. 2021) (First Step Act does not mandate §3553 factor consideration for every reduction)
United States v. Bravo, 203 F.3d 778 (11th Cir. 2000) (§3582(c)(2) does not authorize de novo resentencing and limits consideration to the narrow reduction inquiry)