United States v. Crandall, 25 F. 4th 582 (8th Cir. 2022)

Mr. Crandall argued that the prison sentence for his offense of conviction would be significantly shorter were he sentenced today under the law as amended by the First Step Act. Mr. Crandall had stacked 924(c) convictions that led to a total of 562 months imprisonment. The Eighth Circuit opined that because Congress did not affirmatively make the changes in the First Step retroactive, arguments grounded in the disparity of pre- and post-FSA sentences could not be the basis for a finding of extraordinary and compelling circumstances.

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