William & Mary Law Review Online


Olivia Williams


This Note argues that courts are empowered to, and should, grant compassionate release based solely on the sentencing disparities created by the First Step Act -- specifically, the significant changes to § 924(c)'s sentencing scheme. [...] Part I of this Note provides background on the two relevant sections of the First Step Act: changes to the compassionate release process and changes to the § 924(c) sentencing scheme. Part II examines recent district court opinions addressing § 924(c) sentencing disparities as "extraordinary and compelling reasons" for reduced sentences. Part III argues that courts are empowered to grant compassionate release to inmates convicted of multiple § 924(c) charges under the old sentencing scheme because of the sentencing disparities the First Step Act created. Finally, the Note concludes by urging courts to take the second step Congress was unwilling to take itself. This abstract has been adapted from the author's introduction.