United States v. Rodney Harper, 20-1811

Harper pleaded guilty to a crack‑cocaine offense (21 U.S.C. § 841) and a § 924(c) firearm offense; district court initially sentenced him to 211 months and five years supervised release.
The district court later reduced his federal prison term twice, resulting in a total of 180 months served.
After release, Harper pleaded guilty in state court to three drug offenses; the district court found these undisputed state convictions violated his supervised release.
The district court revoked supervised release and imposed a 36‑month revocation sentence.
Harper moved under the First Step Act § 404(b) for a discretionary reduction to time served; the district court denied relief.
On appeal, the Eighth Circuit reviewed only whether denial of First Step Act relief was an abuse of discretion and affirmed, finding the district court considered the arguments and provided a reasoned basis (deterrence, breach of trust, public safety) for denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of First Step Act reduction was an abuse of discretion	Harper: sentence should be reduced to time served under § 404(b) of the First Step Act	Government/District: court acted within discretion given revocation and safety concerns	No abuse of discretion; denial affirmed
Whether district court had to expressly apply § 3553(a) factors	Harper: court should apply sentencing factors and account for Fair Sentencing Act/First Step Act purposes	District: need not expressly recite § 3553(a); court must show it considered arguments and exercised discretion	Court need not recite § 3553(a) if record shows reasoned exercise of discretion; here it did
Whether the revocation sentence rendered First Step Act relief necessary to avoid exceeding underlying range and to effectuate fairness goals	Harper: revocation pushed him beyond his underlying range and First Step Act/Fair Sentencing Act aim supports reduction	District: reducing would reward breach of trust, undermine deterrence, and raise recidivism/safety risks	Court found district adequately rejected Harper’s fairness argument and credited deterrence/public‑safety concerns

United States v. Hoskins, 973 F.3d 918 (8th Cir. 2020) (First Step Act sentence‑reduction framework)
United States v. Black, 992 F.3d 703 (8th Cir. 2021) (two‑step eligibility and discretion approach)
United States v. Holder, 981 F.3d 647 (8th Cir. 2020) (district court need not make an explicit § 404 discretionary statement if record shows considered exercise of discretion)
United States v. Booker, 974 F.3d 869 (8th Cir. 2020) (discussion of district court discretion in sentencing contexts)
United States v. Haymond, 139 S. Ct. 2369 (2019) (post‑revocation sentence is part of the original penalty)
Johnson v. United States, 529 U.S. 694 (2000) (treating post‑revocation punishment as part of original sentence)