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United States v. Combs

United States Court of Appeals For the Eighth Circuit
Apr 30, 2021
No. 20-2154 (8th Cir. Apr. 30, 2021)

Opinion

No. 20-2154

04-30-2021

United States of America Plaintiff - Appellee v. William Santa Combs Defendant - Appellant


Appeal from United States District Court for the Southern District of Iowa - Eastern [Unpublished] Before KELLY, ERICKSON, and STRAS, Circuit Judges. PER CURIAM.

After considering a number of factors, the district court decided not to reduce William Combs's 210-month prison sentence under the First Step Act. See Pub. L. No. 115-391, 132 Stat. 5194 (2018). Though he challenges the decision on a host of grounds, we affirm.

The Honorable John A. Jarvey, Chief Judge, United States District Court for the Southern District of Iowa.

We conclude that the district court gave a reasoned basis for its decision and did not abuse its discretion. See United States v. McDonald, 944 F.3d 769, 771-72 (8th Cir. 2019) (discussing the standard of review and outlining the two-step analysis for motions under the First Step Act); United States v. Williams, 943 F.3d 841, 844 (8th Cir. 2019) (explaining that the sentencing court must have considered the parties' arguments and have a reasoned basis for its decision). It did not have to consider the statutory sentencing factors before making a decision, nor reduce his sentence even if he was eligible. See § 404(c), 132 Stat. at 5222 ("Nothing in this section shall be construed to require a court to reduce any sentence pursuant to this section."); United States v. Moore, 963 F.3d 725, 727 (8th Cir. 2020) (explaining that, in reviewing a First Step Act motion, "a district court may, but need not, consider the section 3553 factors").

We accordingly affirm the judgment of the district court and grant counsel permission to withdraw.


Summaries of

United States v. Combs

United States Court of Appeals For the Eighth Circuit
Apr 30, 2021
No. 20-2154 (8th Cir. Apr. 30, 2021)
Case details for

United States v. Combs

Case Details

Full title:United States of America Plaintiff - Appellee v. William Santa Combs…

Court:United States Court of Appeals For the Eighth Circuit

Date published: Apr 30, 2021

Citations

No. 20-2154 (8th Cir. Apr. 30, 2021)