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Criminal Law: Amendment 801-Reduction of Sentence-Retroactivity
Staff Report//December 30, 2019
Defendant appealed from the district court’s denial of his motion to reduce his sentence based on Amendment 801 to the Sentencing Guidelines.
Where Amendment 801 was not listed in Sentencing Guidelines §1B1.10(d), there was no authorization for a sentence reduction, nor did the lack of retroactivity pose a due process concern.
Judgment is affirmed.
U.S. v. Eaton (MLW No. 74332/Case No. 19-1798 – 2 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Western District of Missouri, Ketchmark, J.
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