United States v. Julius Stevens
997 F.3d 1307
11th Cir.2021Background
- Stevens pleaded guilty in 1999 to conspiracy to distribute crack cocaine (agreed quantity 50–150 g) and was sentenced to 262 months’ imprisonment plus 5 years supervised release; he completed imprisonment in Jan 2018 and began supervised release.
- Stevens moved under First Step Act §404 seeking a reduced term (to guideline low of 151 months) and termination of supervised release, citing post‑sentence rehabilitation and §3553(a) factors.
- The district court denied relief, ruling Stevens ineligible under the First Step Act (based on actual-conduct quantity) and, alternatively, stating it would not reduce or terminate supervised release—without detailing factors considered.
- On appeal the government conceded Stevens is eligible; the Eleventh Circuit addressed (1) eligibility and (2) whether §3553(a) is mandatory when a court exercises discretion under §404(b).
- The Eleventh Circuit held Stevens is eligible, held §3553(a) consideration is not statutorily required, but vacated and remanded because the district court’s alternative denial lacked the minimum explanation needed for meaningful appellate review.
Issues
| Issue | Plaintiff's Argument | Defendant/District Court's Argument | Held |
|---|---|---|---|
| Eligibility under the First Step Act | Stevens: conviction is a "covered offense" (statutory elements control); thus eligible | District court: ineligible based on actual drug-conduct quantity | Held: Eligibility is determined by statutory offense/conviction elements (Jones); Stevens is eligible |
| Must a district court consider §3553(a) when denying/granting §404(b) relief? | Stevens: §3553(a) factors must be considered | Government/District Court: courts may consider §3553(a) but it is discretionary | Held: Consideration of §3553(a) is permissive, not mandatory under the First Step Act |
| Adequacy of district court’s alternative ruling | Stevens: court failed to explain basis for denying reduction or terminating supervised release | District court: relied on prior findings that sentence was reasonable | Held: District court’s explanation was inadequate for appellate review; reversal and remand required |
| Remedy / guidance on remand | Stevens: urged reduction/termination based on rehabilitation and time served | Government: relief is discretionary | Held: On remand court may (but need not) consider §3553(a), probation submissions, rehabilitation, etc., but must give a reasoned explanation for its exercise of discretion |
Key Cases Cited
- United States v. Jones, 962 F.3d 1290 (11th Cir. 2020) (eligibility under First Step Act depends on statutory offense/elements)
- Gall v. United States, 552 U.S. 38 (2007) (district court must adequately explain sentencing decisions to permit meaningful appellate review)
- Rita v. United States, 551 U.S. 338 (2007) (district courts should set forth enough reasoning to show a reasoned basis for sentencing choices)
- Chavez-Meza v. United States, 138 S. Ct. 1959 (2018) (insufficient explanation requires remand for fuller explanation)
- Dillon v. United States, 560 U.S. 817 (2010) (under §3582(c)(2) courts must consider §3553(a) before reducing sentence)
- Pepper v. United States, 562 U.S. 476 (2011) (post‑sentencing rehabilitation is highly relevant to sentencing)
- United States v. Meeks, 971 F.3d 830 (8th Cir. 2020) (circuit decision that §3553(a) consideration is permissive under First Step Act)