United States v. Johnny Chavis, Jr. ( 2021 )

UNPUBLISHED
UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
No. 20-6741
UNITED STATES OF AMERICA,
Plaintiff - Appellee,
v.
JOHNNY LEE CHAVIS, JR.,
Defendant - Appellant.
Appeal from the United States District Court for the Eastern District of Virginia, at
Newport News. Rebecca Beach Smith, Senior District Judge. (4:06-cr-00023-RBS-FBS-
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Submitted: March 23, 2021 Decided: March 26, 2021
Before THACKER, QUATTLEBAUM, and RUSHING, Circuit Judges.
Vacated and remanded by unpublished per curiam opinion.
Johnny Lee Chavis, Jr., Appellant Pro Se.
Unpublished opinions are not binding precedent in this circuit.
PER CURIAM:
Johnny Lee Chavis, Jr., appeals from the district court’s April 24, 2020, order
denying his motion for reduction of sentence under 18 U.S.C. § 3582(c)(1)(B) and § 404(b)
of the First Step Act of 2018 (FSA 2018), Pub. L. No. 115-391, 132 Stat. 5194, 5222.
The district court determined that Chavis was eligible for relief under these provisions but
declined to exercise its discretion to reduce Chavis’ sentence. Because the district court
decided Chavis’ motion without the benefit of our decision in United States v. McDonald,
986 F.3d 402 (4th Cir. 2021), we vacate and remand.
We review for abuse of discretion the district court’s ruling on Chavis’ motion.
See United States v. Jackson, 952 F.3d 492, 497, 502 (4th Cir. 2020). “A district court
abuses its discretion when it acts arbitrarily or irrationally, fails to consider judicially
recognized factors constraining its exercise of discretion, relies on erroneous factual or
legal premises, or commits an error of law.” United States v. Dillard, 891 F.3d 151, 158
(4th Cir. 2018) (internal quotation marks omitted).
On appeal, Chavis challenges the sufficiency of the district court’s explanation for
denying his motion. In the analogous context of a sentence reduction motion under
18 U.S.C. § 3582(c)(2), the Supreme Court has explained that a district court need only
“set forth enough to satisfy the appellate court that [it] ha[s] considered the parties’
arguments and ha[s] a reasoned basis for exercising [its] own legal decisionmaking
authority.” Chavez-Meza v. United States, 138 S. Ct. 1959, 1966 (2018) (quoting Rita v.
United States, 551 U.S. 338, 356 (2007)). The Supreme Court also emphasized, however,
that the federal courts of appeals have broad discretion “to request a more detailed
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explanation [from the district court] when necessary.” Id. at 1967. After Chavez-Meza,
we issued our decision in United States v. Martin, 916 F.3d 389, 396-97 (4th Cir. 2019),
and concluded that the district court there was obliged to provide an individualized
explanation for denying the § 3582(c)(2) motions when the defendants had submitted
significant evidence of post-sentencing rehabilitation in support thereof. In our recent
decision in McDonald, we applied Chavez-Meza and Martin in the context of a sentence
reduction motion filed pursuant to § 3582(c)(1)(B), and § 404(b) of the FSA 2018.
986 F.3d at 408-12. There, we held that the district court was required to provide an
individualized explanation for denying the sentence reduction motions under the FSA
2018 when the defendants presented significant evidence of their post-sentencing
rehabilitation. Id. at 412. In making that individualized explanation, we stated, the
district court may “consider the facts of [a defendant’s] original transgressions,” but the
court “must also at least weigh [the defendant’s] conduct in the years since [his] initial
sentencing[].” Id.
Here, the district court denied Chavis’ motion without specifically addressing his
post-sentencing rehabilitation arguments. Because the court did not have the benefit of
our decision in McDonald when it ruled on Chavis’ motion, we vacate and remand so that
the district court may reassess Chavis’ motion in light of that decision.
We dispense with oral argument because the facts and legal contentions are
adequately presented in the materials before this court and argument would not aid the
decisional process.
VACATED AND REMANDED
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