United States v. Robinson, 3:01-cr-30044

Anton L. Robinson was convicted after jury trial (Sept. 10, 2002) of conspiracy to possess with intent to distribute 50 grams or more of cocaine base (crack).
He was sentenced on Jan. 14, 2003 to 324 months imprisonment and five years supervised release under the then-mandatory guidelines; the PSR attributed ~41.78 kg of cocaine base to him.
The Fair Sentencing Act (2010) raised crack quantity thresholds; the First Step Act §404 (2018) made those revisions retroactive and authorizes courts to reduce sentences for covered offenses.
Robinson moved under §404 for a reduced sentence (seeking 264 months) and for supervised release to be reduced to four years; the government opposed, arguing (1) ineligibility under the First Step Act and (2) that §3553(a) factors counsel denial.
The court held Robinson is eligible (following Fifth Circuit precedent in Jackson), considered the §3553(a) factors and parties’ arguments, and granted a reduction to 264 months imprisonment and four years supervised release.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eligibility under First Step Act §404	Robinson is ineligible because the PSR attributed a large crack quantity to him (disqualifying)	Eligible because conviction was under a statute whose penalties were modified by the Fair Sentencing Act and committed before Aug. 3, 2010	Eligible — court follows Fifth Circuit in United States v. Jackson that covered-offense status depends on the statute of conviction, not PSR quantity
Whether a sentence reduction is warranted under §3553(a)	Deny reduction: Robinson allegedly a major dealer, gang member, directed others, large quantities attributed, firearms involvement, criminal history	Grant a downward variance: relatively low criminal-history score, no allegation of violence, rehabilitation and prison programming, minimal disciplinary record	Granted — after weighing §3553(a) factors and FSA purpose, court varied downward to 264 months as sufficient but not greater than necessary
Supervised-release term reduction	Implicitly opposes or does not affirmatively support reduction	Requests reduction from 5 years to 4 years	Granted — supervised release reduced to four years

Dorsey v. United States, 567 U.S. 260 (2012) (explaining Fair Sentencing Act changes and temporal application)
United States v. Jackson, 945 F.3d 315 (5th Cir. 2019) (covered-offense inquiry depends on statute of conviction)
United States v. Williams, 943 F.3d 841 (8th Cir. 2019) (courts should consider guidelines and §3553(a) at resentencing)
Pepper v. United States, 562 U.S. 476 (2011) (post-sentencing rehabilitation may be considered at resentencing)