United States v. Eric Williams, 943 F.3d 841

In 2004 Eric L. Williams was sentenced to 20 years for conspiracy to possess with intent to distribute 5 grams or more of crack cocaine.
The Fair Sentencing Act (2010) raised the crack threshold from 5 g to 28 g; Dorsey clarified its temporal application.
The First Step Act (2018) made the Fair Sentencing Act retroactive via §404, allowing courts to "may impose" reduced sentences for covered offenses but stating that nothing requires a court to reduce a sentence.
Williams moved under §404 to reduce his sentence; the district court denied the motion without a hearing, concluding a reduction below 20 years would not satisfy §3553 factors; the sentence remained below the Guidelines range.
Williams appealed, arguing (1) the First Step Act requires a hearing and (2) the district court abused its §3553 discretion by inadequately weighing post‑sentencing rehabilitation and sentencing disparity.
The Eighth Circuit reviewed statutory interpretation de novo and §3553 sentencing decisions for abuse of discretion, and affirmed the district court.

Issue	Williams' Argument	Government/District Court Argument	Held
Whether §404 of the First Step Act requires a hearing before ruling on a §404 motion	"Impose" (vs. "modify") and §404(c)'s "complete review" language mandate a hearing; hearing makes practical sense	§404 is discretionary ("may impose") and expressly says nothing requires reduction; text does not mention or require a hearing	No. The Act does not mandate a hearing; courts may decide §404 motions without one.
Whether the district court abused its discretion by not reducing sentence based on Williams's post‑sentencing rehabilitation	Williams: substantial rehabilitation (no infractions for 9+ years; education/programs) warranted a reduced term	District court considered rehabilitation but was not required to reduce sentence on that basis	No abuse. Courts may consider rehabilitation but need not reduce sentence for it.
Whether the district court erred by failing to address sentencing disparity with co‑conspirators/others	Williams: court failed to account for disparity and comparators	Court considered §3553(a) factors, presentence report, trial evidence, and original transcript; relied on Williams's long trafficking history and amount (over 1 kg) and noted current sentence was below Guidelines	No abuse. Court sufficiently considered arguments and provided a reasoned basis for its decision.

Dorsey v. United States, 567 U.S. 260 (interpreting the Fair Sentencing Act's application to pre‑Act offenses)
Behrens v. United States, 644 F.3d 754 (8th Cir.) (standard: de novo review for statutory interpretation)
Gall v. United States, 552 U.S. 38 (abuse‑of‑discretion review of sentences under §3553)
Pepper v. United States, 562 U.S. 476 (courts may consider postsentencing rehabilitation)
United States v. Hernandez‑Marfil, 825 F.3d 410 (8th Cir.) (district court may decline to adjust sentence despite rehabilitation)
United States v. Keatings, 787 F.3d 1197 (8th Cir.) (district court need not respond to every argument but must show a reasoned basis)
Rita v. United States, 551 U.S. 338 (appellate standard for determining whether sentencing court provided a reasoned basis)