First Step Act applies only to cases sentenced after its enactment

United States v. Jefferson, ___F.3d___, 2021 WL 868496 (10th Cir. 2021) (application of First Step Act to pending cases) The First Step Act is not ambiguous; it says it applies to cases where the sentence “has not been imposed” by December 20, 2018 (date of enactment). Mr. Jefferson’s case was on appeal at that time but he was sentenced in June 2017. “[A] sentence is ‘imposed’ ‘“when the district court announces it, not when appeals are exhausted’.” at *2. Because the FSA is not ambiguous, the rule of lenity does not apply.