Background

• In 2008 Ratliff was convicted by jury of conspiracy and possession with intent to distribute cocaine/crack; jury found each offense involved ≥5 grams of crack. He had prior felony drug convictions and was designated a career offender.
• At sentencing the court applied the career-offender guideline, producing a Guidelines range of 360 months to life; the court imposed concurrent 360-month terms.
• The Fair Sentencing Act (2010) raised the crack thresholds; the First Step Act (2018) authorized district courts to apply those reduced statutory penalties retroactively under §404.
• The district court granted a First Step Act reduction, recalculated Ratliff’s Guidelines as if the Fair Sentencing Act applied, and reduced his concurrent sentences to 262 months.
• Ratliff moved under 18 U.S.C. §3582(c)(1)(A) for further compassionate release, arguing (inter alia) the court erred in continuing to treat him as a career offender and (in district court) cited COVID-19 risks and hypertension. The district court denied relief; Ratliff appealed.
• The Eleventh Circuit affirmed, holding that "extraordinary and compelling reasons" for §3582(c)(1)(A) relief are limited to those in U.S.S.G. §1B1.13 per United States v. Bryant, and Ratliff did not invoke a qualifying reason on appeal (his health claim was abandoned).

Issues

Key Cases Cited

• Kimbrough v. United States, 552 U.S. 85 (background on crack/powder sentencing disparity)
• Dorsey v. United States, 567 U.S. 260 (Fair Sentencing Act effective-date issue)
• United States v. Jones, 962 F.3d 1290 (First Step Act §404 retroactive reduction authority)
• United States v. Bryant, 996 F.3d 1243 (holding "extraordinary and compelling reasons" limited to U.S.S.G. §1B1.13)
• United States v. Puentes, 803 F.3d 597 (district courts may modify sentences only when authorized by statute)
• Jones v. Fla. Parole Comm'n, 787 F.3d 1105 (pro se filings are liberally construed)
• Timson v. Sampson, 518 F.3d 870 (issues not briefed on appeal by a pro se litigant are abandoned)