United States v. Jeffery Wills, 991 F.3d 720

Wills pleaded guilty in 2017 to conspiracy to distribute 50+ grams of methamphetamine; the government filed a § 851 information based on a prior felony drug conviction.
The district court sentenced Wills to the 240‑month mandatory minimum (followed by 10 years supervised release); Wills did not appeal.
After exhausting administrative remedies, Wills moved under 18 U.S.C. § 3582(c)(1)(A) (compassionate release) in Sept. 2020, arguing the First Step Act’s § 401 would mean he no longer qualified for the 20‑year mandatory minimum.
§ 401 of the First Step Act narrowed the prior‑conviction trigger by defining “serious drug felony,” and reduced the mandatory minimum in some cases from 20 to 15 years.
The district court denied relief, reasoning § 401 does not apply retroactively and the ordinary nonretroactive application of a new statute is not an “extraordinary and compelling” basis for sentence reduction.
The Sixth Circuit affirmed, finding no abuse of discretion in the denial and concluding § 401 is not retroactive as to defendants already sentenced when the Act took effect.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the First Step Act’s § 401 amendment is an “extraordinary and compelling” reason for a § 3582(c)(1)(A) sentence reduction	Wills: If sentenced today § 401 would prevent the 20‑year enhancement, so that change is an extraordinary and compelling reason to reduce his sentence	Gov./district court: § 401 does not apply retroactively; the ordinary prospective application of new penalties is not an extraordinary and compelling reason	Denied. Court affirmed the district court’s exercise of discretion; no abuse found
Whether § 401 should reduce Wills’s mandatory minimum from 20 to 15 years	Wills: He should be subject to the 15‑year minimum under § 401	Gov./district court: § 401 expressly does not apply retroactively to those already sentenced; argument fails	Rejected. § 401 is not retroactive and cannot be applied to Wills’s sentence

United States v. Ruffin, 978 F.3d 1000 (6th Cir. 2020) (abuse‑of‑discretion review and § 3582(c)(1)(A) framework)
United States v. Jones, 980 F.3d 1098 (6th Cir. 2020) (district courts have discretion to define extraordinary and compelling reasons for defendant‑filed motions)
United States v. Elias, 984 F.3d 516 (6th Cir. 2021) (USSG § 1B1.13 applies only to BOP motions)
Dorsey v. United States, 567 U.S. 260 (2012) (ordinary practice applies new penalties prospectively for those not yet sentenced)
United States v. Corp, 668 F.3d 379 (6th Cir. 2012) (citation of other courts’ grants does not by itself show abuse of discretion)
United States v. Flowers, 963 F.3d 492 (6th Cir. 2020) (standards for abuse of discretion in sentencing contexts)
United States v. White, 492 F.3d 380 (6th Cir. 2007) (abuse‑of‑discretion precedents)