Background
Michael Ragland was convicted in 2009 of eighteen federal crimes, including armed robberies and firearm offenses, and sentenced to 196 years. In 2022, he successfully moved to vacate one count under the Supreme Court’s decision in Davis, leading to a resentencing that maintained a similar total term. Ragland appealed, arguing the First Step Act should apply to his resentencing. The Eleventh Circuit initially affirmed the District Court, but the Supreme Court’s subsequent decision in Hewitt v. United States rejected that interpretation of the First Step Act.
The court’s reasoning
The court granted rehearing to align with Hewitt, which held that offenders resentenced after the First Step Act’s enactment are subject to its revised penalties, even if their original sentences were imposed earlier. The court clarified that while the District Court had authority to reconsider the entire sentencing package under the package doctrine, it must now apply the First Step Act’s reduced mandatory minimums. Regarding the jurisdictional issue, the court reaffirmed that successive Section twenty-two hundred fifty-five motions require specific appellate certification for each new constitutional claim and cannot be expanded via Rule fifteen amendments without further appellate review.
We grant Ragland’s petition for rehearing and amend our opinion filed on June 24, 2025, but only in part.
Opinion of the Court, Page 3
What it means going forward
Ragland’s sentence is vacated and remanded for the District Court to resentence him according to the First Step Act, potentially reducing his mandatory minimums for subsequent firearm offenses.