United States v. Albert Woodson, 962 F.3d 812

In 2009 Albert Lynn Woodson was sentenced to 151 months for distributing 0.41 grams of crack cocaine under 21 U.S.C. § 841(a)(1) and penalty provision § 841(b)(1)(C).
Woodson sought a sentence reduction under Section 404 of the First Step Act (retroactive application of the Fair Sentencing Act of 2010).
The Fair Sentencing Act raised the crack thresholds in § 841(b)(1)(A)(iii) (50g→280g) and § 841(b)(1)(B)(iii) (5g→28g) but did not change the text of § 841(b)(1)(C).
The district court denied relief, ruling § 841(b)(1)(C) was not “modified” because its text remained unchanged.
The Fourth Circuit vacated and remanded, holding that changing the thresholds in (A) and (B) necessarily altered the scope of (C) and thus “modified” its statutory penalties for First Step Act purposes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Fair Sentencing Act “modified” the statutory penalties of § 841(b)(1)(C) so as to make convictions under it “covered offenses” under the First Step Act	Woodson: Although (C)’s text did not change, its scope changed because (A) and (B) thresholds shifted, so (C) was modified	Government: (C) was not modified because its statutory text (and lack of a mandatory minimum) remained unchanged	Held: Yes. Changing (A)/(B) thresholds changed the range of quantities covered by (C), so (C) was “modified” and Woodson is eligible
Whether First Step Act relief is limited to convictions carrying mandatory minimums	Woodson: First Step Act is not limited to statutes with mandatory minimums; eligibility depends on whether statutory penalties were modified	Government: Relief should be limited to statutes/defendants affected by mandatory minimums	Held: Rejected. First Step Act eligibility is not confined to statutes that impose mandatory minimums

Kimbrough v. United States, 552 U.S. 85 (U.S. 2007) (addresses crack-to-powder sentencing disparity)
United States v. Wirsing, 943 F.3d 175 (4th Cir. 2019) (held threshold changes count as modifications for First Step Act eligibility)
United States v. Gravatt, 953 F.3d 258 (4th Cir. 2020) (same interpretation of § 404 and Section 2 weight changes)
United States v. Chambers, 956 F.3d 667 (4th Cir. 2020) (applies Fair Sentencing Act changes retroactively under First Step Act)
United States v. Smith, 954 F.3d 446 (1st Cir. 2020) (agrees that (b)(1)(C) was modified by threshold changes)
MCI Telecommunications Corp. v. American Tel. & Tel. Co., 512 U.S. 218 (U.S. 1994) (interpretation that "modified" can mean any change)
United States v. Black, 737 F.3d 280 (4th Cir. 2013) (discusses reduced crack-to-powder ratio effect)