United States v. Nolan Nathaniel Edwards, 997 F.3d 1115

Nolan Edwards was convicted in the 1990s of crack-cocaine offenses and, because of prior felony drug convictions, was sentenced to life imprisonment without release under the law then in effect.
The Fair Sentencing Act (2010) reduced penalties for crack offenses; the First Step Act §404(b) (2018) made those reductions retroactive for "covered offenses."
Edwards moved for a sentence modification citing both §404(b) of the First Step Act and 18 U.S.C. §3582(c)(1)(B).
The district court reduced Edwards’ prison term from life without release to 262 months (or time served) and imposed an eight-year term of mandatory supervised release.
Edwards appealed, arguing the First Step Act authorizes only subtraction from a sentence and not the addition of supervised release; the Eleventh Circuit affirmed.

Issue	Edwards' Argument	Gov't Argument	Held
Whether the First Step Act (§404(b)) is a self-executing procedural vehicle or must be pursued via 18 U.S.C. §3582(c)(1)(B)	Edwards invoked both §404(b) and §3582; did not press a distinct procedural claim	§3582(c)(1)(B) must provide the procedural vehicle; §404(b) operates through §3582	The First Step Act §404(b) is self-contained and self-executing; motions may proceed under it without §3582(c)(1)(B)
Whether a district court may impose a new term of supervised release when it "reduces" a sentence under the First Step Act	Edwards: §404(b) only permits reducing sentence; court cannot add supervised release not in the original sentence	Gov’t: §404(b) authorizes reduction of the overall "sentence," and supervised release is a component of a sentence that may be imposed so long as the overall sentence is reduced	The court may impose a new supervised-release term under §404(b) provided the defendant’s overall sentence is reduced

Mont v. United States, 139 S. Ct. 1826 (2019) (holding supervised release is part of a sentence)
Dorsey v. United States, 567 U.S. 260 (2012) (Congress may enact new sentencing rules that apply to later prosecutions)
United States v. Sutton, 962 F.3d 979 (7th Cir. 2020) (First Step Act is its own procedural vehicle)
United States v. Denson, 963 F.3d 1080 (11th Cir. 2020) (First Step Act does not require a hearing with the defendant present)
United States v. Puentes, 803 F.3d 597 (11th Cir. 2015) (district courts may modify sentences only when authorized by statute)
United States v. Wirsing, 943 F.3d 175 (4th Cir. 2019) (held §3582(c)(1)(B) was the appropriate vehicle for First Step Act relief in that case)