United States v. Mario Lomax

Mario Victor Lomax pleaded guilty in 2008 to one count of distributing crack cocaine. See 21 U.S.C. § 841(a)(1). By the time he was sentenced in 2011, Congress had enacted the Fair Sentencing Act of 2010 (“FSA”), Pub L. No. 111-220, 124 Stat. 2372, which increased the threshold amounts of crack that will trigger enhanced statutory penalties under § 841(b)(1). (The parties do not say, and neither does the record disclose, why this prosecution languished; Lomax pleaded guilty more than three years after his arrest and was sentenced nearly three years after that.) Lomax argued that his sentence…