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Federal Relief & Sentencing Developments — February 24–28, 2025
Supreme Court developments, First Step Act litigation, Second Amendment challenges, sentencing reversals, and federal relief considerations affecting post-conviction litigation.
This federal sentencing developments bulletin reviews recent Supreme Court activity, favorable appellate decisions, First Step Act litigation, and evolving federal relief considerations affecting federal prisoners and families.
Federal Sentencing Developments Executive Summary
Recent federal sentencing developments include Supreme Court action involving Second Amendment challenges to federal firearm prohibitions, a significant new trial ruling in the Richard Glossip case, favorable First Step Act earned-time-credit litigation, sentencing reversals, and continuing developments involving compassionate release and federal firearm convictions.
Several recent appellate decisions may affect future litigation involving sentencing enhancements, supervised release calculations, First Step Act eligibility, firearm-related convictions, and post-conviction relief proceedings.
Supreme Court Watch
The Supreme Court released a lengthy order list addressing multiple criminal law matters. Of particular significance, the Court vacated and remanded two Eleventh Circuit cases involving constitutional challenges to federal felon-in-possession statutes for reconsideration under United States v. Rahimi.
The Court also issued a major ruling in Glossip v. Oklahoma, reversing Richard Glossip’s conviction and ordering a new trial after concluding prosecutors failed to correct false testimony presented during the proceedings.
These developments continue to shape litigation involving firearm restrictions, due process protections, and constitutional challenges within the federal criminal justice system.
Federal Appellate Victories
United States v. Ashe (3rd Circuit)
The Third Circuit vacated a sentence after finding insufficient evidence to support a firearm enhancement involving an AK-style pistol discovered months after the defendant’s incarceration.
United States v. Parham (4th Circuit)
The Fourth Circuit vacated a sentence after determining that Virginia robbery may not qualify as a crime of violence for federal sentencing enhancement purposes.
Valladares v. Ray (4th Circuit)
The Fourth Circuit ruled that First Step Act earned-time-credit exclusions based on drug offenses resulting in death require an actual conviction for the death-resulting enhancement, not merely factual allegations.
United States v. Brown (10th Circuit)
The Tenth Circuit reversed a murder conviction after finding the jury should have received instructions concerning imperfect defense of another and involuntary manslaughter.
United States v. Davis (10th Circuit)
The Tenth Circuit ordered resentencing after finding an improper criminal-history enhancement had been applied.
Federal Relief Considerations
Recent litigation continues to highlight potential relief opportunities involving:
- First Step Act earned-time credits;
- Federal firearm convictions under 18 U.S.C. § 922(g);
- Compassionate release arguments involving stacked sentences;
- Sentencing enhancement challenges;
- Career offender and criminal history calculations; and
- Post-conviction litigation under federal relief statutes.
Individuals with older federal firearm convictions, sentencing enhancements, or First Step Act eligibility disputes may benefit from reviewing recent appellate developments.
Educational Purpose Notice
This publication is provided for educational and informational purposes only. It is not legal advice and does not create an attorney-client relationship or legal representation.