United States v. Cornelius Rivers, 19-7046

Cornelius Deon Rivers, pro se, appealed a district court order that partially granted his motion for a sentence reduction under § 404 of the First Step Act of 2018.
At original sentencing Rivers had received Guidelines calculations including a career-offender enhancement; he challenged those calculations in his First Step Act motion.
The district court accepted that Rivers would no longer qualify as a career offender for its § 3553(a) analysis but declined to recalculate his original Guidelines range when ruling on the motion.
The Fourth Circuit vacated and remanded the district court’s order for reconsideration in light of intervening Fourth Circuit decisions (Chambers, Collington, Lancaster) that require Guidelines recalculation and correction of Guidelines errors where appropriate.
The court expressed no view on the ultimate merits of Rivers’ motion, denied appointment of counsel, and dispensed with oral argument.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must a district court recalculate the Guidelines when imposing a new sentence under the First Step Act?	Rivers: yes — court must recalculate the Guidelines range.	Government/District Court: court need not always recalc; may rely on original calculations.	Court: Recalculation is required when imposing a new sentence (Chambers).
Must courts correct original Guidelines errors and apply intervening case law in First Step Act proceedings?	Rivers: yes — correct errors and apply retroactive/intervening authority.	Government: deference to original sentence or limited review.	Court: Courts must correct retroactive Guidelines errors and may apply intervening case law (Collington).
Is a First Step Act proceeding a plenary resentencing?	Rivers: seeks full reconsideration consistent with current law.	Government/District Court: proceeding is limited, not a full relitigation.	Court: Not a plenary resentencing but must fill "gaps" from the original sentencing—recalculate Guidelines and consider § 3553(a) in light of intervening circumstances (Lancaster).
What standard governs review of a court's decision to reduce a sentence under the Act?	Rivers: reduced sentence must be procedurally and substantively reasonable.	Government: discretion for district court; appellate review deferential.	Court: District court’s decision reviewed for abuse of discretion; reduced sentences must be procedurally and substantively reasonable (Collington; Jackson).

United States v. Chambers, 956 F.3d 667 (4th Cir. 2020) (when imposing a new sentence under the First Step Act, courts must recalculate the Guidelines range)
United States v. Collington, 995 F.3d 347 (4th Cir. 2021) (three-step framework: recalc Guidelines, correct Guidelines errors/apply intervening law, consider § 3553(a); require procedural and substantive reasonableness)
United States v. Lancaster, 997 F.3d 171 (4th Cir. 2021) (First Step Act proceedings require brief analysis recalculating Guidelines in light of intervening law but are not plenary resentencings)
United States v. Jackson, 952 F.3d 492 (4th Cir. 2020) (review of district court’s decision to grant First Step Act relief is for abuse of discretion)
Gall v. United States, 552 U.S. 38 (2007) (district courts must provide adequate explanation to avoid procedural unreasonableness)
United States v. Norman, 935 F.3d 232 (4th Cir.) (example of intervening authority invalidating a career-offender enhancement)