32 F.4th 653
7th Cir.2022Background
- Adam Williams was convicted in 2001 of (1) conspiracy to distribute >50g crack, (2) distributing >50g crack, and (3) distributing >5g crack; originally sentenced to life on Counts 1–2 and 40 years on Count 3 (concurrent).
- After unsuccessful post-judgment reductions, a 2014 resentencing reduced Williams’s aggregate term to 360 months based on changed Guidelines ranges and offense factors.
- The First Step Act §404 (2018) made the Fair Sentencing Act’s lower crack penalties retroactive; under the amended statutes Williams’s Counts 1–2 carried 60–480 months and Count 3 carried a statutory maximum of 240 months.
- Williams moved in 2019 for further reduction under the First Step Act; Judge Moody denied relief but did not calculate the new statutory ranges and misstated the Count 3 maximum as 360 months.
- The Seventh Circuit found the district court procedurally required to calculate amended statutory ranges before ruling, concluded the failure was plain error (deprived Williams of the anchoring effect of the new ranges), vacated the denial, and remanded for reconsideration.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court erred by denying a First Step Act §404 motion without calculating the new statutory ranges | Williams: Judge Moody insufficiently explained denial and failed to apply new statutory benchmarks; Williams’s disciplinary record and rehabilitation support reduction | Government/Judge: 360-month sentence already complies with First Step Act; offense seriousness justifies denial | Vacated and remanded — district court must calculate amended statutory ranges; failure was plain error requiring reconsideration |
| Whether appellate court should order immediate reduction of Count 3 to the new statutory maximum | Williams urged the court to follow Fourth Circuit (Collington) and reduce Count 3 to at most the new maximum | Government opposed; court should let district court decide in first instance | Denied as an appellate fix — court declined to adopt automatic reduction and left remedy to district court on remand |
Key Cases Cited
- United States v. Blake, 22 F.4th 637 (7th Cir. 2022) (district court must calculate new penalties before deciding First Step Act motions)
- United States v. Corner, 967 F.3d 662 (7th Cir. 2020) (procedural requirements for First Step Act motions)
- United States v. Shaw, 957 F.3d 734 (7th Cir. 2020) (new judge should independently assess First Step Act motion and not be overly reliant on prior explanations)
- Molina-Martinez v. United States, 578 U.S. 189 (2016) (sentencing ranges have an anchoring effect central to sentencing fairness)
- Rosales-Mireles v. United States, 138 S. Ct. 1897 (2018) (errors affecting sentencing benchmarks ordinarily warrant relief on review)
- Olano v. United States, 507 U.S. 725 (1993) (plain-error review framework)
- Henderson v. United States, 568 U.S. 266 (2013) (definition of plain error at time of appellate review)
- United States v. Collington, 995 F.3d 347 (4th Cir. 2021) (court-ordered reduction to new statutory maximum under First Step Act — relied on by defendant but not adopted here)