United States v. Aaron Woods, 949 F.3d 934

In 2001 Woods pled guilty to drug offenses including possession with intent to distribute 125 g of crack; also received a consecutive 60‑month §924(c) firearm sentence; total sentence was 181 months (later reduced in 2008 to 120 months).
Woods began supervised release in 2015, committed new state felony offenses and tested positive for drugs. His supervised release was revoked and he was sentenced to 37 months, which he is currently serving.
After the First Step Act (2018), Woods moved for a sentence reduction; the district court followed its procedures, ordered a probation recalculation, and ultimately denied relief.
The probation office concluded Woods was not entitled to a reduction; Woods (through counsel) objected arguing he had already overserved his original sentence.
The district court assumed Woods was eligible under the First Step Act but denied a reduction after weighing his conduct on supervised release and public‑safety concerns; Woods appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a defendant serving a post‑revocation sentence is eligible for First Step Act relief	Woods: his current revocation term is part of the original covered offense, so he is eligible	Gov: originally argued ineligibility because sentence is for supervised‑release violation but withdrew that position	Court: Eligible — postrevocation sentence is part of original penalty for a covered offense (First Step Act may apply)
Whether district court abused discretion in denying a reduction (consideration of overservice and weight of state convictions)	Woods: court failed to give proper weight to his overserved original sentence and overemphasized state convictions	Gov/District Court: court properly considered overservice but reasonably relied on violation conduct, ongoing drug/weapon involvement, and deterrence/public‑safety factors	Court: No abuse of discretion — record shows court considered overservice and permissibly denied reduction based on sentencing factors

United States v. Beamus, 943 F.3d 789 (6th Cir. 2019) (First Step Act enables retroactive application of Fair Sentencing Act §2)
United States v. Blewett, 746 F.3d 647 (6th Cir. 2013) (Fair Sentencing Act not retroactive absent First Step Act)
Johnson v. United States, 529 U.S. 694 (2000) (postrevocation penalties relate to the original offense)
United States v. Johnson, 640 F.3d 195 (6th Cir. 2011) (postrevocation sentence is part of the penalty for the original offense)
United States v. Venable, 943 F.3d 187 (4th Cir. 2019) (revocation sentence can be a covered offense under First Step Act)
United States v. Davis, 458 F.3d 505 (6th Cir. 2006) (court must show it considered overservice)
United States v. Watkins, 625 F.3d 277 (6th Cir. 2010) (abuse‑of‑discretion standard for sentencing adjustments)
United States v. Phinazee, 515 F.3d 511 (6th Cir. 2008) (affirming discretion in revocation sentencing)