Supreme Court Sends ‘First Step’ Case Back to the Eleventh Circuit

December 15, 2022

Hard work by dedicated criminal defense lawyers paid off for Nathaniel Fields, a federal prisoner whose defenders took his appeal all the way to the highest court in the nation.

In our case of the week, the Eleventh Circuit in United States v. Nathaniel Fields, 2022 U.S. App. LEXIS  32756 *, 2022 WL 17258435, Case No.  19-13927 (decided November 29, 2022) revised his case on remand from the Supreme Court of the Untied States.  In 2019 Mr. Fields filed a motion for sentence reduction under § 404(b) of the First Step Act of 2018. The district court granted his motion in part and imposed a lesser sentence, but it denied a request to recompute his U.S. Sentencing Guidelines range without a career-offender designation under changes to the Guidelines. Mr. Fields then appealed, and the Eleventh Circuit affirmed, relying on its prior opinion in United States v. Denson, 963 F.3d 1080, 1089 (11th Cir. 2020).

The Supreme Court vacated the prior judgement of the Eleventh Circuit in Mr. Field’s case and remanded in light of v. United States, 142 S.Ct. 2900 (2022). Conception held that “the First Step Act allows district courts to consider intervening changes of law of fact in exercising their discretion to reduce a sentence pursuant to the First Step Act.” See Id. at 2404. As courts must “consider nonfrivolous arguments presented by the parties, the First Step Act requires district courts to consider intervening changes when parties raise them.” Id. at 2396 (“however, the First Step Act does not compel courts to exercise their discretion to reduce any sentence based on those arguments.”)

Conception teaches that federal district courts ruling on First Step Act motions “bear the standard obligation to explain their decisions,” and must “give a “brief statement of reasons” to show they considered the parties’ arguments. 2404. “All that the First Step Act requires is that a district court make clear that it reasoned through the parties’ arguments.” Id.

In Fields, the district court’s order showed it considered the parties’ arguments, including the argument that changes in the Guidelines favored a sentence reduction, but the order did not state whether the court understood it could consider intervening changes to the U.S. Sentencing Guidelines. See Concepcion at 2396, 2404. Therefore, the Eleventh Circuit vacated the judgment of the district court and remanded for further proceedings in light of Concepcion.

Defendant Nathaniel Fields had the benefit of the effective assistance of criminal defense counsel dedicated to his case. Qualified criminal defense lawyers have the know-how to fight judicial decisions deemed to be wrong-minded “all the way to the U.S. Supreme Court,” and, sometimes, the law changes. The admirable work of Mr. Fields’s criminal defense lawyers should benefit him and all other similarly situated defendants.

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