United States v. Sutton, 2:05-cr-20044

Sutton was indicted in 2005 on Counts 1–3 for crack and powder cocaine offenses; the government filed a §851 notice seeking a 20-year mandatory minimum based on a 1997 marijuana-distribution conviction.
Sutton pleaded guilty in 2005; in 2006 the court designated him a career offender and sentenced him to 30 years imprisonment (concurrent) with supervised release terms (10 years on Counts 1–2, 8 years on Count 3).
Sutton has served over 183 months; BOP records show low security classification, extensive educational/vocational courses, satisfactory work history, and minimal disciplinary incidents.
Sutton moved under §404 of the First Step Act (2018) for a sentence reduction to time served and supervised release reduced to eight years. The government opposed, arguing ineligibility based on drug-quantity attribution.
The court found Sutton’s offenses were "covered offenses" under the First Step Act (following the Fifth Circuit in Jackson), considered §3553(a) factors, noted that a full resentencing is not authorized, and concluded relief was warranted.
The court granted the motion: reduced imprisonment to time served effective June 24, 2020; reduced supervised release on Counts 1–2 to eight years (to run concurrent with Count 3); imposed a six-month halfway-house residency as a special condition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eligibility under First Step Act §404	Sutton is ineligible because drug-quantity attributed at sentencing places him outside the Fair Sentencing Act’s revised thresholds.	Sutton is eligible because he was convicted under statutes whose penalties were modified by the Fair Sentencing Act and his offense pre-dated Aug 3, 2010.	Court held Sutton is eligible; quantity-based ineligibility argument foreclosed by Fifth Circuit in Jackson.
Whether reduction is warranted (relief on merits / §3553(a))	If eligible, any reduction should account for statutory range, guidelines, and deterrence; government urged consideration of §3553(a).	Sutton requested reduction to time served and supervised release reduction, citing rehabilitation, length of time served, and changed statutory minima.	Court found time served sufficient and not greater than necessary after weighing §3553(a), post‑sentencing rehabilitation, and sentencing history; granted reduction and imposed six‑month halfway-house condition.

Dorsey v. United States, 567 U.S. 260 (explaining the Fair Sentencing Act reform of crack/powder sentencing disparities)
United States v. Jackson, 945 F.3d 315 (5th Cir.) (holding covered-offense status depends on the statute of conviction, not quantity at sentencing)
U.S. v. Hegwood, 934 F.3d 414 (5th Cir.) (First Step Act does not permit plenary resentencing)
Pepper v. United States, 562 U.S. 476 (authorizing consideration of post-sentencing rehabilitation at resentencing)
United States v. Williams, 943 F.3d 841 (8th Cir.) (discussing First Step Act relief and appellate guidance on consideration of sentencing factors)
United States v. Allen, 956 F.3d 355 (6th Cir.) (addressing scope of district court consideration when granting First Step Act relief)