The U.S. Court of Appeals for the Eighth Circuit affirmed a district court's denial of a sentence reduction request from a defendant serving a mandatory life sentence for crack cocaine offenses, marking another case where eligibility for First Step Act relief does not guarantee a reduced sentence.
Zechariah Benjamin, also known as "Boo," sought a sentence reduction under Section 404 of the First Step Act of 2018, a criminal justice reform law that allows certain prisoners to petition for resentencing. The Eighth Circuit issued an unpublished per curiam opinion on Jan. 6, 2026, affirming the lower court's decision in the case *United States v. Zechariah Benjamin* (8th Cir. 2026).
Benjamin's legal troubles stem from a 2008 jury conviction for distributing and conspiring to distribute crack cocaine in the U.S. District Court for the Northern District of Iowa. At that time, he received a mandatory life imprisonment sentence under federal sentencing guidelines that have since been modified by Congress.
The severity of Benjamin's sentence was largely due to his criminal history. He had at least two prior convictions for delivering cocaine in Illinois, which enhanced his sentence under 21 U.S.C. § 841(b)(1)(A). This federal statute provides for increased penalties when a defendant has two or more prior convictions for certain predicate offenses, triggering the mandatory minimum life sentence that was required at the time of his conviction.
The legal landscape for crack cocaine offenses changed with the passage of the First Step Act in 2018. This bipartisan criminal justice reform legislation reduced the disparity between crack and powder cocaine sentences and provided retroactive relief for certain prisoners. Section 404 of the Act specifically allows district courts to reduce sentences for prisoners whose offenses had penalties modified by the Fair Sentencing Act of 2010.
In 2024, Benjamin filed a motion seeking a sentence reduction under the First Step Act's provisions. The case presented an interesting dynamic where both sides agreed on Benjamin's technical eligibility for relief. The government conceded that Benjamin qualified for resentencing under the statute, acknowledging that the legal framework for his original sentence had changed.
However, eligibility and entitlement proved to be two different matters. Despite agreeing that Benjamin could seek resentencing, the government opposed his motion, arguing that life imprisonment remained the appropriate sentence given the circumstances of his case and criminal history. This position reflects the prosecutorial discretion that remains even under the reformed sentencing structure.
Chief Judge C.J. Williams of the U.S. District Court for the Northern District of Iowa handled Benjamin's resentencing motion. Following the government's recommendation, Judge Williams determined that while Benjamin was eligible for resentencing consideration, the facts of his case did not warrant a reduction in his prison sentence. The district court's decision effectively meant that Benjamin would continue serving his life sentence despite the changes in federal sentencing law.
Benjamin appealed the district court's denial to the Eighth Circuit Court of Appeals. The case was submitted to a three-judge panel consisting of Circuit Judges Smith, Gruender, and Shepherd on Sept. 19, 2025. The court's per curiam opinion, issued approximately four months later, unanimously affirmed the lower court's decision without identifying a single author for the opinion.
The Eighth Circuit's brief opinion reflects the deferential standard of review typically applied to district court sentencing decisions. Under the First Step Act, district courts have discretion in determining whether to grant sentence reductions even when defendants meet the eligibility criteria. Courts consider various factors including the nature of the offense, criminal history, post-conviction conduct, and public safety concerns.
This case illustrates the practical limitations of the First Step Act's relief provisions. While the legislation expanded opportunities for sentence reductions and addressed some of the harshest aspects of federal drug sentencing, it did not create an automatic right to reduced sentences. Defendants must still demonstrate that a sentence reduction is warranted based on the totality of circumstances.
The unpublished nature of the Eighth Circuit's opinion suggests the court viewed this as a routine application of established First Step Act precedent rather than a case raising novel legal issues. Unpublished opinions, while not precedential, still provide guidance on how courts are interpreting and applying the criminal justice reform legislation.
Benjamin's case represents one of thousands of First Step Act petitions filed since the law's enactment. While many defendants have received sentence reductions, others like Benjamin have found that meeting the technical eligibility requirements does not guarantee relief. The law's implementation continues to evolve as courts balance the reform legislation's goals with traditional sentencing considerations including deterrence and public safety.
The decision leaves Benjamin to continue serving his life sentence while highlighting the ongoing challenges facing long-term federal prisoners seeking relief under criminal justice reform measures.