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192685P.pdf   05/27/2021  United States  v.  Antwoyn Spencer
   U.S. Court of Appeals Case No:  19-2685
                          and No:  19-2691
   U.S. District Court for the District of Minnesota   
   [PUBLISHED] [Benton, Author, with Colloton and Kelly, Circuit Judges] 
   Criminal Case - First Step Act. After two brothers were convicted of 
   conspiring to distribute both cocaine and powder cocaine, they sought 
   reduction under the First Step Act. Eligibility depends on whether a 
   "covered offense" includes a multidrug conspiracy distributing both crack 
   and powder cocaine. Covered offense require modification under the Fair 
   Sentencing Act, including all penalties triggered by the drug-quantity 
   element, not just the highest tier of penalties. First Step Act was not 
   limited to single-drug conspiracies. The Spencers were thus eligible for 
   resentencing under the First Step Act.