康塞普西翁诉美国案

Carlos Concepcion was sentenced in 2008 to 19 years for distributing crack cocaine under then-mandatory guidelines. Following the Fair Sentencing Act of 2010 and the First Step Act of 2018, which reduced crack-powder sentencing disparities and made reforms retroactive, Concepcion filed a motion for sentence reduction. The district court denied relief without considering intervening legal and factual changes, ruling it lacked authority to do so. The First Circuit affirmed. The Supreme Court granted certiorari to resolve a circuit split on whether district courts must consider intervening changes of law and fact when adjudicating First Step Act resentencing motions.

The Supreme Court ruled 5-4 in favor of Concepcion. Justice Sonia Sotomayor authored the majority opinion, holding that district courts not only may but must consider all intervening changes of law and fact when deciding First Step Act resentencing motions. The Court emphasized that Congress intended to restore broad discretion to sentencing judges, allowing them to account for subsequent legal reforms, post-sentencing conduct, and other relevant circumstances. Justice Brett Kavanaugh dissented, joined by three other justices.

Whether a district court, when ruling on a motion for sentence reduction under Section 404 of the First Step Act, may consider intervening changes of law or fact beyond the Fair Sentencing Act's modified statutory penalties, or whether its analysis must be confined solely to the retroactive guideline amendments.

This ruling significantly expanded the scope of judicial discretion under the First Step Act, allowing thousands of federal inmates to present evidence of rehabilitation and benefit from subsequent sentencing reforms. It reinforced Congress's intent to remedy racially disproportionate crack cocaine sentences that disproportionately affected African American communities. The decision prompted renewed review of numerous pending resentencing petitions nationwide, advanced criminal justice reform objectives, and affirmed the judiciary's role in ensuring individualized sentencing assessments rather than mechanical application of outdated guidelines.