United States v. Havens

Robert E. Wier, United States District Judge *629The narrow question before the Court is whether the First Step Act of 2018's broadening of 18 U.S.C. § 3553(f) (i.e. , the statutory "safety valve") applies to a defendant who pleaded guilty before the Act became law but was sentenced after that date. The answer turns on the meaning of "conviction entered" in § 402(b) of the Act. Because the Court concludes that conviction entry, in context, corresponds with pronouncement of guilt rather than date of judgment, it finds the § 402 changes inapplicable in this pre-Act plea scenario.

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Timothy Havens…