A defendant has avoided a 15-year mandatory sentence under a federal repeat-felony offender law because New York’s 2004 Drug Law Reform Act downgraded his prior convictions to less than “serious” offenses.

Southern District of New York Judge Richard Holwell found that two prior Class C felonies for defendant Ralph Archer would have earned him the federal minimum had the state Legislature not changed the indeterminate sentencing scheme of the Rockefeller drug laws.

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