In United States v. Ragland, the United States Court of Appeals for the Eleventh Circuit addressed whether a defendant resentenced after the vacatur of a firearm conviction may benefit from the sentencing reforms enacted in the First Step Act.[i] The case highlights how recent Supreme Court precedent continues to reshape federal sentencing law, particularly for defendants who received lengthy sentences under the former “stacking” framework of 18 U.S.C. § 924(c).
Michael Shane Ragland was convicted in 2009 for his role in a series of armed robberies of Florida convenience stores. A federal jury found him guilty of eighteen counts, including multiple violations of § 924(c), which criminalizes using or brandishing a firearm during a crime of violence. At the time of Ragland’s sentencing, § 924(c) contained a stacking mechanism that imposed increasingly severe mandatory minimum sentences for multiple firearm convictions charged in the same indictment. After a defendant’s first § 924(c) conviction, each additional conviction carried a mandatory minimum sentence of twenty-five years to be served consecutively. As a result of this structure, Ragland received a sentence totaling 196 years in federal prison.
In the years following his conviction, developments in Supreme Court precedent created new opportunities for defendants to challenge firearm convictions predicated on certain offenses. Ragland sought relief through a motion under 28 U.S.C. § 2255, relying on United States v. Taylor, in which the Supreme Court held that attempted Hobbs Act robbery does not qualify as a “crime of violence” for purposes of § 924(c).[ii] Because one of Ragland’s firearm convictions was predicated on attempted Hobbs Act robbery, the district court vacated that count and ordered resentencing.
At resentencing, Ragland argued that the district court should apply the First Step Act of 2018.[iii] The Act significantly altered § 924(c)’s sentencing framework by eliminating the automatic stacking of twenty-five-year mandatory minimum sentences when multiple firearm charges are brought in the same case. Instead, the enhanced penalty now applies only when a defendant commits a new § 924(c) offense after a prior conviction has become final. The district court declined to apply the First Step Act and resentenced Ragland to 173 years in prison.
Ragland appealed, and the Eleventh Circuit initially affirmed the district court’s decision based on its prior precedent interpreting the First Step Act’s retroactivity. However, only two days after the panel issued its opinion, the Supreme Court decided Hewitt v. United States.[iv] In Hewitt, the Court held that defendants who appear for sentencing after the enactment of the First Step Act, including those whose earlier sentences were vacated, are subject to the Act’s revised sentencing provisions.[v]
In light of Hewitt, the Eleventh Circuit granted Ragland’s petition for rehearing.[vi] The court concluded that because Ragland’s sentence had been vacated and he appeared before the district court for a new sentencing proceeding, the First Step Act’s revised penalties applied. The Court therefore vacated Ragland’s sentence and remanded the case for resentencing consistent with the Act.
The court also rejected Ragland’s attempt to expand his § 2255 motion to challenge additional firearm convictions. The Eleventh Circuit held that district courts lack jurisdiction to consider claims beyond those authorized by the court of appeals in a successive § 2255 motion. In doing so, the court declined to follow approaches adopted by other circuits that allow broader amendments to post-conviction petitions.
The decision in Ragland reflects the continuing impact of both legislative reform and Supreme Court intervention on federal sentencing. By applying the Supreme Court’s guidance in Hewitt, the Eleventh Circuit confirmed that defendants whose sentences are vacated and reconsidered after the First Step Act may benefit from Congress’s effort to reduce the harsh consequences of § 924(c) stacking.
[i] See United States v. Ragland, No. 23-12278, 2025 WL 1742251, 2 (11th Cir. Mar. 5, 2026).
[ii] See United States v. Taylor, 596 U.S. 824, 1-3 (2022).
[iii] See First Step Act of 2018, Pub. L. No. 115-391, § 403, 132 Stat. 5194, 5221-22 (2018).
[iv] See Hewitt v. United States, 145 S. Ct. 2165, 1 (2025).
[v] See First Step Act of 2018, supra note iii.
[vi] See Hewitt, 145 S. Ct. at 2-3; see also Ragland No. 23-12278 at 1.