United States v. Christopher Lancaster, 997 F.3d 171

Background

Lancaster pleaded guilty in 2009 to conspiracy to distribute cocaine powder and crack in violation of 21 U.S.C. § 846 and was sentenced in 2010 to 180 months after the court relied on his career‑offender status to set the Guidelines range.
The Probation Report attributed large drug quantities but the court sustained some objections and chose to sentence as a career offender rather than make drug‑weight findings.
The Fair Sentencing Act (2010) raised crack‑threshold quantities; the First Step Act (2018) made those changes retroactive and authorized district courts to reduce sentences “as if” the Fair Sentencing Act had been in effect.
Lancaster moved under the First Step Act in 2020 seeking a reduced sentence, arguing that intervening law means he no longer qualifies as a career offender and that a recalculated Guidelines range would yield a much lower sentence.
The district court denied relief on the merits, stating it would have imposed the same sentence had the Fair Sentencing Act been in effect, but it did not recalculate Guidelines under intervening case law nor expressly revisit the § 3553(a) factors.
The Fourth Circuit vacated and remanded, holding the district court must perform the brief analysis required by precedent: recalculate the Guidelines where gaps remain (including addressing career‑offender status) and reconsider § 3553(a) factors in light of current circumstances.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Is Lancaster eligible for First Step Act relief?	Lancaster: his § 846 offense was a "covered offense" committed before Aug 3, 2010 and he filed in the sentencing court.	Gov: relief discretionary but eligibility elements are met.	Court: Eligible — statutory criteria satisfied; merits decision remains discretionary.
2. Must the district court recalculate the Guidelines in light of intervening case law when deciding a First Step Act motion?	Lancaster: yes — intervening law (e.g., Norman/McCollum) can negate his career‑offender status, so Guidelines must be recalculated.	Gov: the district court reasonably concluded sentence would be the same without a full recalculation.	Court: Yes — per Chambers and related precedent, court must recalculate where intervening law affects Guidelines and fill gaps from original sentencing.
3. Must the court reconsider 18 U.S.C. § 3553(a) factors (including post‑sentencing conduct) in deciding whether to reduce the sentence?	Lancaster: yes — courts may and should consider § 3553(a) and post‑sentencing conduct when exercising First Step Act discretion.	Gov: district court implicitly considered the merits and denied relief.	Court: Yes — a brief reweighing of § 3553(a) in light of current circumstances is required (and may include post‑sentencing conduct).
4. Does Lancaster still qualify as a career offender under current Fourth Circuit law?	Lancaster: no — subsequent Fourth Circuit decisions treat § 846 conspiracies as not categorical controlled‑substance offenses, so career‑offender enhancement no longer applies.	Gov: original sentencing relied on career offender; district court concluded it would still impose same sentence.	Court: The later decisions (Norman, McCollum, Whitley) call the career‑offender classification into question; because the district court made no drug‑weight findings, this gap must be addressed on remand.

Key Cases Cited

United States v. Chambers, 956 F.3d 667 (4th Cir. 2020) (district courts must correct retroactive Guidelines errors in First Step Act resentencings)
United States v. Wirsing, 943 F.3d 175 (4th Cir. 2019) (§ 3582(c)(1)(B) is vehicle for First Step Act motions)
United States v. Gravatt, 953 F.3d 258 (4th Cir. 2020) (defining eligibility for First Step Act covered offenses)
United States v. Woodson, 962 F.3d 812 (4th Cir. 2020) (First Step Act covered‑offense scope includes certain § 841(b) provisions)
United States v. Norman, 935 F.3d 232 (4th Cir. 2019) (§ 846 conspiracy not categorically a controlled‑substance offense for career‑offender purposes)
United States v. McCollum, 885 F.3d 300 (4th Cir. 2018) (same principle regarding § 846 and career‑offender predicates)
United States v. White, 984 F.3d 76 (D.C. Cir. 2020) (§ 3553(a) factors may be considered in First Step Act proceedings)
United States v. Peters, 843 F.3d 572 (4th Cir. 2016) (§ 3582(c)(2) context — district court may need more precise attribution of drug quantity)