United States v. Cory McNeal

CourtCourt of Appeals for the Sixth Circuit
DecidedNovember 1, 2023
Docket22-5847
StatusUnpublished

This text of United States v. Cory McNeal (United States v. Cory McNeal) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth 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. Cory McNeal, (6th Cir. 2023).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 23a0457n.06

No. 22-5847

UNITED STATES COURT OF APPEALS FILED FOR THE SIXTH CIRCUIT Nov 01, 2023 KELLY L. STEPHENS, Clerk ) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE UNITED ) STATES DISTRICT COURT FOR v. ) THE EASTERN DISTRICT OF ) TENNESSEE CORY MCNEAL, ) Defendant-Appellant. ) OPINION ) )

Before: GIBBONS, BUSH, and DAVIS, Circuit Judges.

JOHN K. BUSH, Circuit Judge. Cory McNeal moved for a discretionary sentence

reduction under the First Step Act. The district court declined McNeal’s request, leaving in place

his 262-month sentence. McNeal contends that the court abused its discretion. It did not, so we

affirm.

I.

A. Initial Sentencing

Cory McNeal pleaded guilty in 2008 to conspiring to distribute, and to possessing with the

intent to distribute, 5 grams or more of cocaine base (“crack”) and 500 grams or more of cocaine,

in violation of 21 U.S.C. §§ 841(a)(1) and 841(b)(1)(B). Because McNeal had prior convictions

for possessing and delivering drugs, and because his instant offense qualified as a “controlled

substance offense” at the time, the district court sentenced him as a career offender under U.S.S.G.

§ 4B1.1. Under that Guidelines enhancement, a defendant’s base offense level is determined by No. 22-5847, United States v. McNeal

the statutory maximum sentence he may receive. U.S.S.G. § 4B1.1(b). And because of the

quantity of drugs that McNeal possessed in his instant offense, the government filed a discretionary

notice under 21 U.S.C. § 851 that McNeal was subject to a mandatory sentence of ten years to life

imprisonment. Because the § 851 enhancement increased his statutory maximum sentence to life,

his base offense level rose to 37. From there, the district court reduced his offense level by 3 points

because he pleaded guilty and, based on his revised offense level and criminal history category of

VI, calculated a Guidelines range of 262 to 327 months’ imprisonment. All told, McNeal was

sentenced in 2009 to 262 months’ imprisonment and 8 years’ supervised release.

B. Post-Sentencing Developments

Just a year later, Congress passed the Fair Sentencing Act, which reduced the sentencing

disparity between crack cocaine and powder cocaine offenses from 100-to-1 to 18-to-1. Pub. L.

No. 111-220, § 2, 124 Stat. 2372, 2372 (2010). Congress made those changes retroactive when it

passed the First Step Act in 2018. Pub. L. No. 115-391, § 404, 132 Stat. 5194, 5222 (2018).

Usually, a court “may not modify a term of imprisonment once it has been imposed.” 18 U.S.C.

§ 3582(c). But an exception to that rule states that a court “may modify an imposed term of

imprisonment to the extent otherwise expressly permitted by statute.” Id. § 3582(c)(1)(B).

Through the First Step Act, courts have discretion to modify sentences that meet the statute’s

requirements. See United States v. Maxwell, 991 F.3d 685, 689 (6th Cir. 2021).

Section 404 of the First Step Act permits a defendant to move for a reduced sentence if

(i) he committed a “covered” offense, or one for which the statutory penalty was modified by §§ 2

or 3 of the Fair Sentencing Act; (ii) his offense was committed before August 3, 2010; and (iii) he

had not previously moved for and been denied a sentence reduction under the First Step Act. § 404,

2 No. 22-5847, United States v. McNeal

132 Stat. at 5222. Even if the defendant qualifies for a sentence reduction, nothing in the First

Step Act requires a court to reduce his sentence. Id. at § 404(c).

The First Step Act also reduced some mandatory minimums and altered the prerequisites

for certain enhanced recidivist penalties. § 401, 132 Stat. at 5220. This included requiring that

the predicate offense for an enhancement under 21 U.S.C. § 851 be a “serious drug felony” or

“serious violent felony,” rather than a “felony drug offense.” § 401(b), 132 Stat. at 5221 (changing

the language found in 21 U.S.C. § 841). However, the revised penalties in § 401 are not available

to defendants sentenced before December 21, 2018. § 401(c), 132 Stat. at 5221; see also United

States v. Bonds, 858 F. App’x 873, 876 (6th Cir. 2021) (“Because the First Step Act became

effective on December 21, 2018, well after [the defendant] received his enhanced sentence, any

retroactive effects of section 401 do not apply to [him].”).

C. Procedural History

In 2020, McNeal moved pro se for a sentence reduction under the First Step Act. His

motion was then supplemented several times by counsel, and he ultimately requested the court

reduce his sentence to 188 months. Relying on this court’s decision in United States v. Havis, 927

F.3d 382 (6th Cir. 2019) (en banc) (per curiam), McNeal contended that he no longer qualified for

the career offender enhancement.1 He also argued that, because § 401 of the First Step Act

provides that only a “serious drug felony” qualifies as a predicate offense triggering a § 851

enhancement, he was not subject to that enhancement either. Finally, he asked the court to consider

his rehabilitative efforts and what his sentence would be if he was sentenced today when balancing

the 18 U.S.C. § 3553(a) factors.

1 In a supplemental brief, McNeal acknowledged that he “remain[ed] in the career offender guideline” because his offense included conspiracy to distribute over 500 grams of cocaine. Supp. Mot. for Imposition of a Reduced Sentence Pursuant to Section 404 of the First Step Act, R. 620, PageID 2614.

3 No. 22-5847, United States v. McNeal

The government conceded that McNeal was eligible for a sentence reduction because the

Fair Sentencing Act reduced the statutory penalty for convictions involving crack under

§ 841(b)(1)(B). But it disagreed that his sentence should be reduced. Because McNeal was

convicted of conspiring to distribute both 5 grams crack and 500 grams cocaine, and because the

Fair Sentencing Act did not reduce the statutory penalty for a cocaine conviction under

§ 841(b)(1)(B), the government explained that McNeal’s Guidelines range would not change after

applying the Fair Sentencing Act. In other words, McNeal’s conspiracy to distribute triggered the

same statutory penalty in 2020 as it did in 2009.

The district court determined that McNeal was eligible for a sentence reduction but that a

reduction was not warranted. It agreed with the government that because McNeal was convicted

of conspiring to distribute 500 grams of cocaine, the Fair Sentencing Act did not affect his

Guidelines range or his career offender status. The court did not remove the § 851 enhancement

but noted that it had “considered” the effect § 401 of the First Step Act would have had if the

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