United States v. Rahmaan El Herman, 971 F.3d 784

Rahmaan El Herman was convicted in 2008 of crack and powder cocaine offenses and sentenced in the Northern District of Iowa to 180 months imprisonment and five years supervised release.
In 2019 he moved under Section 404(b) of the First Step Act to reduce his sentence to 92 months and to reduce supervised release to four years.
While the motion was pending, El Herman completed his prison term, began supervised release, and the Northern District of Iowa transferred jurisdiction over him to the Northern District of Illinois under 18 U.S.C. § 3605.
The Northern District of Iowa dismissed El Herman’s First Step Act motion without prejudice for lack of jurisdiction after the transfer.
The Northern District of Illinois later denied El Herman’s First Step Act motion; he did not appeal that denial to the Seventh Circuit.
The Eighth Circuit affirmed the dismissal by Northern Iowa, holding the transferee court (N.D. Ill.) had jurisdiction to consider First Step Act relief once jurisdiction was transferred under § 3605.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a sentencing court retains jurisdiction to decide a First Step Act §404(b) motion after transferring jurisdiction over a person on supervised release under 18 U.S.C. §3605	El Herman: §404(b) authorizes “a court that imposed a sentence” to reduce it, so the original sentencing court (N.D. Iowa) retained authority despite the transfer	Government/Transferee: §3605 authorizes the transferee court to exercise all powers over the releasee that the transferee would have under the sentencing statutes, so jurisdiction moves with the transfer	The transferee court (N.D. Ill.) has jurisdiction; transferor court lacked authority after transfer, so dismissal was proper

Parker Drilling Mgmt. Servs., Ltd. v. Newton, 139 S. Ct. 1881 (2019) (statutes must be read together when enacted against a common statutory backdrop)
United States v. Fernandez, 379 F.3d 270 (5th Cir. 2004) (§3605 permits transferee court to take full jurisdiction from transferor)
United States v. Clark, [citation="405 F. App'x 89"] (8th Cir. 2010) (per curiam) (transferor court lacks jurisdiction to exercise powers after transfer)
Miller v. McClain, 249 U.S. 308 (1919) (grant of greater statutory power includes lesser powers)
United States v. Schrader, 973 F.2d 623 (8th Cir. 1992) (same principle regarding implied lesser powers)
United States v. O'Neil, 11 F.3d 292 (1st Cir. 1993) (same principle regarding statutory powers and transfers)