United States v. Benjamin

CourtCourt of Appeals for the Second Circuit
DecidedJanuary 30, 2023
Docket19-3636-cr
StatusUnpublished

This text of United States v. Benjamin (United States v. Benjamin) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Benjamin, (2d Cir. 2023).

Opinion

19-3636-cr United States v. Benjamin

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

1 At a stated term of the United States Court of Appeals for the Second Circuit, held 2 at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New 3 York, on the 30th day of January, two thousand twenty-three. 4 5 PRESENT: 6 JOHN M. WALKER, JR., 7 REENA RAGGI, 8 EUNICE C. LEE, 9 Circuit Judges. 10 ------------------------------------------------------------------ 11 UNITED STATES OF AMERICA, 12 13 Appellee, 14 15 v. No. 19-3636-cr 16 17 NEAL BENJAMIN, 18 19 Defendant-Appellant. * 20 ------------------------------------------------------------------ 21 22 For Appellee: Katherine A. Gregory, Assistant 23 United States Attorney, for Trini 24 E. Ross, United States Attorney 25 for the Western District of New 26 York, Buffalo, NY. 27 28 For Defendant-Appellant: Jonathan I. Edelstein, Edelstein & * The Clerk of Court is respectfully directed to amend the official caption as set forth above.

1 1 Grossman, New York, NY. 2 Neal Benjamin, pro se, White 3 Deer, PA. 4 5 6 Appeal from a judgment of the United States District Court for the Western District of New

7 York (Richard J. Arcara, J.).

8 UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

9 DECREED that the judgment of the district court is AFFIRMED.

10 Defendant-Appellant Neal Benjamin appeals from the district court’s denial of his

11 resentencing motion brought pursuant to Section 404 of the First Step Act, Pub. L. No. 115-391,

12 132 Stat. 5194 (2018). Following a jury trial, Benjamin was convicted in 1999 of one count of

13 conspiracy to distribute and possess with intent to distribute an unspecified amount of cocaine,

14 cocaine base, and marijuana (“Count 1”), in violation of 21 U.S.C. § 846 as it relates to 21 U.S.C.

15 § 841(a)(1) and (b)(1)(C), and one count of distribution and possession with intent to distribute an

16 unspecified amount of cocaine base (“Count 3”), in violation of 21 U.S.C. §§ 841(a)(1) and

17 (b)(1)(C). In 2008, the court sentenced Benjamin to a maximum 20 years on Count 1 and 10 years

18 on Count 3, to be served consecutively for a total of 30 years. The sentence was affirmed on

19 appeal. United States v. Benjamin, 391 Fed. App’x 942 (2d Cir. 2010).

20 In 2019, Benjamin filed a First Step Act motion to reduce his sentence. The First Step Act

21 made the Fair Sentencing Act of 2010, Pub. L. No. 111-220, 124 Stat. 2372, retroactively

22 applicable. First Step Act, Pub. L. No. 115-391, Sec. 404. The Fair Sentencing Act narrowed the

23 sentencing disparity between cocaine and cocaine base (otherwise known as “crack”) offenses by

24 increasing the amount of crack required for conviction of certain offenses carrying mandatory

25 minimum and/or increased maximum sentences. Fair Sentencing Act, Pub. L. No. 111-220, Sec.

26 2. To be eligible for a sentence reduction under the First Step Act, a defendant must have been

2 1 convicted of a “covered offense,” i.e., an offense for which the Fair Sentencing Act changed the

2 statutory penalty. First Step Act, Pub. L. No. 115-391, Sec. 404; see Terry v. United States, 141

3 S. Ct. 1858, 1862 (2021). The district court denied Benjamin’s motion, finding him ineligible for

4 relief because his convictions for drug crimes subject to § 841(b)(1)(C)’s penalties are not covered

5 offenses under the First Step Act.

6 On appeal, Benjamin, through counsel, urges the court to hold that crimes subject to

7 § 841(b)(1)(C) penalties are covered offenses within the meaning of the First Step Act when the

8 total sentence imposed exceeds § 841(b)(1)(C)’s 20-year maximum. Benjamin also argues, pro

9 se, that (1) he was in fact sentenced under 21 U.S.C. § 841(b)(1)(A) (pondering, inter alia, a 10-

10 year-to-life sentencing range for crimes involving certain drug quantities), making his a conviction

11 for a covered offense; (2) the district court’s factfinding at sentencing violated his Sixth

12 Amendment rights; and (3) Congress’ failure to provide a First Step Act remedy to defendants

13 sentenced under § 841(b)(1)(C) violates the Equal Protection Clause.

14 We conclude that the district court properly denied Benjamin’s First Step Act motion and

15 reject Benjamin’s pro se arguments. We assume the parties’ familiarity with the underlying facts,

16 procedural history, and issues on appeal, to which we refer only as necessary to explain our

17 decision to affirm.

18 The denial of a motion for a discretionary sentence reduction is typically reviewed for

19 abuse of discretion. United States v. Holloway, 956 F.3d 660, 664 (2d Cir. 2020). However, that

20 standard applies only where the district court exercised its discretion in the first instance. Id.

21 Where, as here, the district court determines that a defendant is ineligible for a discretionary

22 sentence reduction based entirely on statutory interpretation, we review that determination de

23 novo. Id.

3 1 I. Counseled Arguments

2 The Supreme Court’s decision in Terry v. United States, which held that crimes subject to

3 § 841(b)(1)(C) penalties are not covered offenses within the meaning of the First Step Act, is

4 dispositive of this appeal. 141 S. Ct. at 1864. Terry makes clear that because § 841(b)(1)(C) has

5 no minimum crack quantity requirement, 1 the Fair Sentencing Act did not modify the statutory

6 penalty for crimes subject to § 841(b)(1)(C) penalties. Id. at 1863. “Before [the Fair Sentencing

7 Act of] 2010, the statutory penalties for [§ 841(b)(1)(C)] were 0-to-20 years, up to a $1 million

8 fine, or both, and a period of supervised release. After 2010, these statutory penalties remain

9 exactly the same.” Id. at 1862–63. As such, a crime subject to § 841(b)(1)(C) penalties is not a

10 “covered offense” for purposes of the First Step Act. Id.

11 Benjamin seeks to distinguish Terry on the basis that the petitioner in that case received a

12 15-and-a-half-year sentence, under the 20-year maximum of § 841(b)(1)(C). Id. at 1861. Because

13 Benjamin received two consecutive sentences under § 841(b)(1)(C), totaling 30 years, he

14 maintains that his sentence exceeds the statutory 20-year maximum penalty authorized by §

15 841(b)(1)(C). But Benjamin did not receive a sentence outside the 20-year statutory maximum

16 authorized by § 841(b)(1)(C); he received two sentences within the statute’s range. The district

17 court’s decision to run these two distinct sentences consecutively, for a total term exceeding that

18 statutorily-authorized sentence for a single conviction, is a perfectly permissible outcome that was

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Lehnhausen v. Lake Shore Auto Parts Co.
410 U.S. 356 (Supreme Court, 1973)
United States v. Holloway
956 F.3d 660 (Second Circuit, 2020)
Travelers Insurance v. 633 Third Associates
14 F.3d 114 (Second Circuit, 1994)
Winston v. City of Syracuse
887 F.3d 553 (Second Circuit, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Benjamin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-benjamin-ca2-2023.