United States v. Curtis Edmonds, 700 F.3d 146

Edmonds was convicted by a jury of a drug conspiracy to distribute more than 50 grams of crack cocaine (Jan 2007–Jun 2008) and three counts of distributing more than 5 grams (Feb 2008).
The district court sentenced Edmonds on Aug 3, 2010 to life imprisonment for the conspiracy count and 360 months on each distribution count, all concurrent.
This Court affirmed in part in Edmonds, 679 F.3d 169 (4th Cir. 2012), upholding conspiracy participation, distribution counts, and predicate-felony determinations.
The Supreme Court in Dorsey v. United States held that the Fair Sentencing Act applies to offenders sentenced after its effective date if sentenced after that date, altering the mandatory-minimum regime.
After Dorsey, the Supreme Court vacated this Court’s Edmonds decision and remanded for reconsideration in light of Dorsey.
Upon remand, this Court reaffirms the prior factual and dispositive conclusions but vacates Edmonds’ sentence and remands for resentencing under the Fair Sentencing Act’s provisions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Fair Sentencing Act applies on remand.	Edmonds contends the FSA benefits should govern on remand.	US Defends that application of FSA is appropriate on remand as required by Dorsey.	Yes; FSA applies on remand and requires resentencing.
Whether the prior sufficiency of the conspiracy verdict remains valid.	Evidence supported Edmonds’ conspiracy participation.	Evidence insufficient only if FSA affects core predicates; otherwise remains valid.	Convictions affirmed; sufficiency preserved on remand.
Whether the sentence should be vacated and resentenced.	Remand for consideration of FSA-based sentences.	No need to alter sentence beyond FSA considerations.	Sentence vacated and remanded for resentencing under the Fair Sentencing Act.
Whether Dorsey’s reasoning necessitates changing the prior life sentence for the conspiracy.	Dorsey supports applying the higher-minimum provisions under FSA.	Dorsey does not change the factual determinations already made.	Dorsey does not implicate the prior findings; but remand remains for FSA-based resentencing.
Whether the predicate North Carolina drug offenses remain valid predicates after remand.	North Carolina predicates qualify under §841(b)(1)(A).	No challenge to predicate status on remand.	Predicates remain valid for purposes of the remand ruling.

United States v. Edmonds, 679 F.3d 169 (4th Cir. 2012) (affirmed conspiracy participation and sentencing factors; predicate offenses qualified)
Dorsey v. United States, 132 S. Ct. 2321 (U.S. 2012) (Fair Sentencing Act applied to offenders sentenced after its effective date)