United States v. Jamel Easter, 975 F.3d 318

Easter was convicted in 2008 of federal crack-cocaine and a firearms offense; the district court held him responsible for 343.55 grams of crack, and originally sentenced him to 228 months (168 drug + 60 firearms, consecutive).
Amendment 782 (2014) lowered certain Guidelines offense levels; the district court granted a retroactive reduction in 2015, reducing Easter’s drug sentence to 135 months (plus the unchanged 60-month consecutive gun term).
The First Step Act §404 (2018) made portions of the Fair Sentencing Act retroactive and authorized courts to “impose a reduced sentence” for covered offenses; Easter moved for resentencing under §404.
The district court found Easter eligible under §404 but denied relief because recalculating the Guidelines (based on the higher drug-quantity the court attributed to Easter) produced the same Guidelines range as after Amendment 782; the court did not address other §3553(a) factors or Easter’s post‑sentencing rehabilitation.
The Third Circuit reviewed whether district courts, when deciding §404 motions, must consider all applicable §3553(a) sentencing factors and held they must; it vacated and remanded for reconsideration because the district court limited analysis to the Guidelines.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a district court must consider all applicable 18 U.S.C. §3553(a) factors when deciding a §404 First Step Act motion	Easter: the court must reconsider §3553(a) factors (including post‑sentence rehabilitation) before granting or denying §404 relief	Govt/District Ct: consideration of §3553(a) is permissive; if amended Guidelines leave range unchanged, resentencing is unnecessary	Held: Yes. Courts must consider all applicable §3553(a) factors (failure to do so is reversible error)
Whether a defendant is entitled to a plenary de novo resentencing or a hearing under §404	Easter sought a resentencing hearing and consideration in person	Govt: §404 does not authorize plenary resentencing or an automatic hearing	Held: No plenary resentencing or guaranteed presence/hearing; but the court must meaningfully consider §3553(a) factors on the record
How eligibility under §404 is determined (statute of conviction vs. drug quantity attributed at sentencing)	Easter: eligibility based on his conviction as a covered offense	Govt: eligibility should depend on drug quantity attributed at sentencing	Held: Eligibility turns on the statute of conviction (district court here found Easter eligible and government did not appeal that ruling)

Dillon v. United States, 560 U.S. 817 (2010) (describes §3582 sentence‑modification provisions as a narrow exception to sentence finality)
Rita v. United States, 551 U.S. 338 (2007) (explains sentencing statutes and the relationship between §3553(a) and the Guidelines)
Pepper v. United States, 562 U.S. 476 (2011) (post‑sentencing rehabilitation may be highly relevant to resentencing)
United States v. Tomko, 562 F.3d 558 (3d Cir. 2009) (requires meaningful, not merely rote, consideration of §3553(a) factors)
United States v. Grier, 475 F.3d 556 (3d Cir. 2007) (remand appropriate where district court failed to consider §3553(a) factors)
United States v. Boulding, 960 F.3d 774 (6th Cir. 2020) (held that at minimum courts must recalculate amended Guidelines and reconsider §3553(a) factors under §404)
United States v. Chambers, 956 F.3d 667 (4th Cir. 2020) (held §3553(a) factors apply in §404 resentencing proceedings)
United States v. Hegwood, 934 F.3d 414 (5th Cir. 2019) (characterizes §404 action as imposing, not merely modifying, a sentence and applies §3553(a))
United States v. Jackson, 964 F.3d 197 (3d Cir. 2020) (clarifies eligibility under §404 turns on statute of conviction and reviews scope of district court authority)