United States v. Thacker, 4 F.4th 569 (7th Cir. 2021)

Holds that the non-retroactive FSA change to § 924(c) cannot constitute an extraordinary and compelling reason for a sentencing reduction. While the stacked 924c can be part of the 3553a calculus, it does not create ECR (not even in combination with other factors). Another upsetting development in the circuit split landscape here.