United States v. Richard Hoskins, 973 F.3d 918

Background

In August 2009 Hoskins pleaded guilty under a Rule 11(c)(1)(C) plea to conspiracy to distribute 50+ grams of crack and agreed to a 327‑month sentence; the PSR treated him as a career offender with a Guidelines range of 324–405 months, and the district court accepted the plea and sentence.
After the First Step Act §404 was enacted, the district court appointed counsel to evaluate whether previously sentenced defendants (including Hoskins) were eligible for sentence reductions.
The district court circulated a proposed order expressing doubt about §404 eligibility and indicating it would deny relief; both parties requested extensions and filed responses.
The district court entered a final order denying §404 relief, explaining Hoskins faced a mandatory life sentence when he pleaded guilty, that the plea reflected multiple factors (maximum exposure, cooperation, career‑offender status), and that even if eligible the court would decline to reduce the sentence.
The government later withdrew its ineligibility position in light of this court’s precedents that eligibility turns on the statute of conviction (offense, not conduct); the Eighth Circuit held Hoskins’ conviction is a covered offense but affirmed the district court’s denial of relief.
The court found the district court provided a reasoned basis for denial, reasonably considered relevant §3553(a) factors (though §404 does not mandate a §3553(a) analysis), and did not abuse its broad discretionary authority to deny a reduction.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hoskins is eligible for relief under First Step Act §404	Hoskins: conviction statute is a covered offense; plea stipulation to larger conduct should not defeat eligibility	Government initially: ineligible because plea stipulated larger quantities; later withdrew ineligibility argument	Eligible: First Step Act applies to offenses (statute of conviction), so Hoskins is eligible despite plea stipulation
Whether the district court violated §404(c) by not providing a "complete review" before denying relief	Hoskins: denial lacked a "complete review on the merits" and denied a reasonable opportunity to be heard	Government: district court considered briefs and had reasoned basis; no further procedure required	No violation: district court stated it considered briefs, explained its reasoning, and provided a reasoned basis for denial
Whether the district court abused its discretion by declining to reduce the sentence (including alleged failure to consider §3553(a), rehabilitation, and that plea avoided a mandatory life sentence)	Hoskins: court failed to give sufficient weight to §3553(a) factors, rehabilitation, and that he avoided a now‑inapplicable mandatory life term	Government: §404 gives district courts broad discretion; court considered applicable §3553(a) factors and plea context	No abuse: §404 does not require a §3553(a) analysis for discretionary reductions; the district court considered relevant factors and reasonably declined relief

Key Cases Cited

United States v. Banks, 960 F.3d 982 (8th Cir. 2020) (First Step Act eligibility depends on offense statute, not conduct)
United States v. McDonald, 944 F.3d 769 (8th Cir. 2019) (same principle: Act applies to offenses)
United States v. Howard, 962 F.3d 1013 (8th Cir. 2020) (district court uniquely positioned to assess discretionary reduction)
United States v. Harris, 960 F.3d 1103 (8th Cir. 2020) (interpreting §404 eligibility)
United States v. Moore, 963 F.3d 725 (8th Cir. 2020) ("complete review" requires consideration of arguments and a reasoned basis)
Rita v. United States, 551 U.S. 338 (2007) (reasoned basis standard for sentencing explanations)
United States v. Timberlake, 679 F.3d 1008 (8th Cir. 2012) (district court exercises sentencing discretion)
United States v. Williams, 943 F.3d 841 (8th Cir. 2019) (district courts commonly consider §3553(a) factors in First Step Act decisions)