Concepcion v. United States

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Concepcion v. United States is a Supreme Court case about whether district courts can use new laws or new facts to reduce a person’s sentence.

What happened
- Carlos Concepcion was arrested in 2006 for selling crack cocaine. He pleaded guilty in 2008 to distributing five grams of crack.
- His sentence carried a mandatory minimum, which was higher because of an earlier conviction. He ended up with a 19-year sentence.
- The 2010 Fair Sentencing Act increased the amount of crack needed to trigger the mandatory minimum, but it did not apply to Concepcion retroactively.
- In 2018, Congress passed the First Step Act. It allowed retroactive relief and gave district courts the discretion to reduce sentences under certain rules.

The legal issue
- Concepcion asked for a sentence reduction under Section 404(b) of the First Step Act.
- He also argued that one of his prior convictions should not count as a career offender anymore because that conviction had been vacated.

Lower courts
- The district court denied his request.
- The First Circuit Court of Appeals agreed, saying Section 404(b) does not create a new proceeding and that reducing a sentence is discretionary.

Supreme Court decision
- The Supreme Court granted review and heard the case on January 19, 2022.
- On June 27, 2022, the Court reversed the First Circuit in a 5–4 decision.
- The Court held that the First Step Act allows district courts to consider intervening changes of law or fact when deciding whether to reduce a sentence.

Who wrote the opinions
- Majority: Justice Sonia Sotomayor (joined by Justices Clarence Thomas, Stephen Breyer, Elena Kagan, and Neil Gorsuch).
- Dissent: Justice Brett Kavanaugh (joined by Chief Justice John Roberts, Justices Samuel Alito, and Amy Coney Barrett).