Published on: Saturday, February 25, 2023

In First Step Act "safety valve" news, the Fourth Circuit adds its name to the "and means and and not or" column. It joins the Ninth and Eleventh Circuits, while staring at them across the other side of the "will no one rid me of this troublesome split" are the Fifth, Sixth,  Seventh, and Eighth Circuits.

The case is United States v. Cassity Jones, No. 21-4605 (4th Cir. Feb. 21, 2023).