Whether appellate review for 'abuse of discretion' of a district court's denial of a sentence reduction under Section 404(b) of the First Step Act requires review of both substantive and procedural reasonableness, or only review of procedural errors

QUESTION PRESENTED FOR REVIEW Where a district court exercises its discretion under Section 404(b) of the First Step Act to deny a sentence reduction to a defendant with a “covered offense” who is indisputably eligible for a reduction under Section 404(a), does appellate review for “abuse of discretion” necessitate review of that denial for both substantive and procedural reasonableness (the rule in the Fourth, Sixth, Seventh, and Eighth Circuits), or only review of procedural errors such as the failure to “consider” the defendant’s arguments and adequately explain the denial of relief—without any review of the substantive reasonableness of maintaining the prior sentence (the rule in the Fifth and Eleventh Circuits)? i INTERESTED PARTIES Pursuant to Sup. Ct. R. 14.1(b)(i), there are no