USA v. Purdy

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UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
United States of America, 	Crim. No. 20-77 (SRN/BRT)
Plaintiff,
v. 	ORDER
Jeffrey Colin Purdy,
Defendant
LeeAnn Bell, Office of the United States Attorney, 300 South Fourth Street, Suite 600,
Minneapolis, Minnesota 55415, for Plaintiff United States of America
Jeffrey Colin Purdy, Pro Se Defendant
SUSAN RICHARD NELSON, United States District Judge
Pending before the court is Defendant Jeffrey Colin Purdy’s Pro Se Motion to
Correct the Court’s January 29, 2025 Order on Motion to Reduce Sentence – Amendment
821 (“Motion to Correct”) [Doc. No. 370].
When Mr. Purdy filed his Motion to Correct, he simultaneously filed a Notice of
Appeal to the Eighth Circuit [Doc. No. 372], appealing the same January 29, 2025 Order
[Doc. No. 369] that he seeks to correct in the instant motion. 	The Eighth Circuit denied
his appeal [Doc. No. 383]. Due to a filing oversight in the District Court’s Clerk’s Office,
however, the Eighth Circuit’s mandate, which returns jurisdiction to this Court, was not
docketed in the District Court until April 30, 2026 [Doc. No. 394].
CASE 0:20-cr-00077-SRN-BRT Doc. 395 Filed 04/30/26 Page 1 of 2

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In his Motion to Correct, Mr. Purdy contends that in the January 29, 2025 Order,
the Court “mislabeled” his underlying Amendment 821 Motion [Doc. No. 347] as a motion
to reduce his sentence, when he merely sought to “correct” his original criminal history
category based on Amendment 821. (Mot. to Correct at 1.)
Irrespective of the label attached to his motion, at the time Mr. Purdy filed his
Amendment 821 Motion, he had already served the custodial portion of his 60-month
original sentence. As the Court explained in the January 29, 2025 Order, retroactive relief
is unavailable under Amendment 821 for a completed sentence. 	(Jan. 29, 2025 Order at
1.) The Eighth Circuit summarily affirmed this Court’s ruling. (8th Cir. J. [Doc. No. 383].)
Accordingly, based upon the foregoing, and all the files, record, and proceedings
herein, IT IS HEREBY ORDERED that Defendant’s Pro Se Motion to Correct [Doc. No.
370] is DENIED.
Dated: April 30, 2026
s/Susan Richard Nelson
SUSAN RICHARD NELSON
United States District Judge
CASE 0:20-cr-00077-SRN-BRT Doc. 395 Filed 04/30/26 Page 2 of 2