Henry

BACKGROUND

Henry is serving a 70-month sentence imposed by the United States District Court for the District of Alaska for a conviction of possession with intent to distribute controlled substances in violation of 21 U.S.C. § 841(a)(1), (b)(1)(B) and (b)(1)(c). Henry’s current projected release date is April 14, 2022. Cruz Dec. ¶ 3, Exs. 1 and 2. According to Henry’s presentence report, a search of Henry’s car produced, among other things, a Ruger .9mm LC9 handgun, loaded and found inside the pocket of Henry’s jacket. Cruz Dec. ¶ 21, Ex. 8. In the presentence report, the Probation Office recommended a two-level enhancement under U.S.S.G. § 2D1.1(b)(1) for possession of a dangerous weapon during the commission of the offense. Cruz Dec. ¶ 22, Ex. 7. The district court adopted the recommendation of the presentence report and applied the two-level gun enhancement. Cruz Dec. ¶ 22, Ex. 9. After Henry completed the RDAP program, she learned that she was not eligible for the reduction of sentence that some inmates receive after completion of the program because of the two-level enhancement for possession of a firearm. Pet’s Ex. 1, ECF 1-10-16. She filed a motion in the United…