United States v. Willie Haynes
968 F.3d 869
| 8th Cir. | 2020Background:
- In 2009 Haynes pleaded guilty to possession with intent to distribute ≥5 grams of cocaine base.
- At sentencing the court attributed 28.35 grams of relevant conduct, producing an advisory range of 262–327 months (total offense level 34); the court varied downward and imposed 188 months.
- The Fair Sentencing Act (2010) reduced crack-cocaine thresholds and penalties; because Haynes had two prior drug felonies his statutory range was reduced from 10 years–life to 0–30 years.
- The First Step Act §404 (2018) allows courts to reduce sentences for offenses whose statutory penalties were modified by the Fair Sentencing Act; eligibility turns on whether the Fair Sentencing Act modified the penalties for the offense of conviction as charged in the indictment.
- In 2019 Haynes moved under the First Step Act; the district court recalculated an advisory range of 188–235 months but denied relief, stating it would have imposed the same 188 months after considering the 18 U.S.C. §3553(a) factors.
- The Eighth Circuit affirmed: the district court acknowledged eligibility and properly exercised discretion in denying a reduction and denying a resentencing hearing.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Haynes was eligible for a First Step Act reduction given drug-quantity attribution | Haynes: court used relevant-conduct quantity; he is eligible because the indictment quantity triggers the Fair Sentencing Act change | District court/Govt: court recognized modification and eligibility but exercised discretion; no categorical eligibility error | Affirmed — court did not err; it acknowledged eligibility and exercised discretion to deny reduction |
| Whether the district court erred in denying a resentencing hearing or abused its §3553(a) discretion | Haynes: entitled to a hearing to show a reduction is warranted | District court: hearing not required; even with new guideline range it would impose same 188-month sentence under §3553(a) | Affirmed — no entitlement to a hearing and no abuse of discretion in denying reduction |
Key Cases Cited
- United States v. McDonald, 944 F.3d 769 (8th Cir. 2019) (eligibility under First Step Act depends on penalties for the offense charged in the indictment, not on relevant-conduct quantity)
- United States v. Williams, 943 F.3d 841 (8th Cir. 2019) (defendant is not entitled as a matter of right to a resentencing hearing under the First Step Act)