USA b. Karriece Quontrel Davis, 20-13835

Davis was sentenced in the Northern District of Florida for counterfeit currency and multiple cocaine‑base (crack and powder) offenses; total sentence 144 months and eight years supervised release (concurrent terms).
PSI attributed ~9.9 g crack and 1,594.3 g powder cocaine; Davis objected to drug‑quantity calculations at sentencing.
After release, Davis (pro se) moved in the Northern District of Florida to terminate supervised release and sought relief under the First Step Act §404(b).
The district court denied relief but treated Davis’s filing under 18 U.S.C. §3583(e) (early termination of supervised release) and did not address First Step Act eligibility on the merits.
On appeal Davis argued the Northern District lacked jurisdiction (claiming supervision had been transferred to the Middle District of Georgia) and that the district court erred by not applying the First Step Act.
The Eleventh Circuit found no record of any transfer of supervision, held the sentencing court retained jurisdiction, and concluded the district court applied the wrong legal standard for the First Step Act—vacating and remanding for correct consideration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction to hear First Step Act motion	Northern Dist. of Fla. lacked jurisdiction because supervision was transferred to Middle Dist. of Ga.	No record of a transfer; sentencing court retained jurisdiction under 18 U.S.C. §3605	Northern District retained jurisdiction; no transfer appeared in the record
Proper legal framework for Davis’s motion	District court failed to address First Step Act §404(b) and instead denied under §3583(e)	District court treated and defended denial as a §3583(e) ruling (denial "without prejudice to renew")	Court held district court applied incorrect statute and abused discretion by not assessing First Step Act eligibility; vacated and remanded
Whether First Step Act authorizes relief for Davis’s convictions	Davis sought relief under First Step Act as if Fair Sentencing Act had applied	If conviction is under §841(b)(1)(C) it is not a "covered offense" and thus not eligible; courts must consult record to determine coverage	Court instructed district court to determine eligibility under controlling precedent (Jones, Terry) on remand; emphasized district court must apply First Step Act standard

United States v. Jones, 962 F.3d 1290 (11th Cir. 2020) (procedural guidance: consult record to determine whether offense is a "covered offense" and courts may exercise discretion under First Step Act)
United States v. Edwards, 997 F.3d 1115 (11th Cir. 2021) (First Step Act authorizes district court to modify criminal sentences, including supervised release)
Terry v. United States, 141 S. Ct. 1858 (2021) (Fair Sentencing Act changed only subparagraphs A and B; §841(b)(1)(C) is not covered)
United States v. Lopez, 562 F.3d 1309 (11th Cir. 2009) (standard of review for jurisdictional transfer questions)
Diveroli v. United States, 803 F.3d 1258 (11th Cir. 2015) (abuse of discretion occurs when a court applies an incorrect legal standard)
United States v. Berry, 701 F.3d 374 (11th Cir. 2012) (Fair Sentencing Act not retroactive to pre‑enactment sentences)