Williams v. USA
Denial of §2255 Sentence Vacatur Under FSA, 'Alleyne', 'Descamps' Rulings Is Explained
June 08, 2017 at 12:00 AM
2 minute read
District Judge Sandra Feuerstein
Williams pleaded guilty to possessing and conspiring to distribute 50 or more grams of “crack” cocaine in violation of 21 USC §§841(a)(1), (b)(1)(A), and 846. At the time, he was serving an eight-year state prison sentence for a prior state drug sales conviction. Between the plea hearing and sentencing the government filed an information that Williams was subject to a mandatory minimum 20-year enhanced prison sentence under the pre-Fair Sentencing Act of 2010 (FSA) version of §841(b)(1)(A)(iii) then in effect. Williams did not appeal sentence of 240 months imprisonment, concurrent to his state sentence, with credit for time served since his state sentence began on May 15, 2002. Reduction of sentence from 240 months to 188 months pursuant to the FSA was denied because the FSA cannot be applied retroactively to reduce a sentence that became final prior to its enactment. District court denied Williams vacatur of sentence under 28 USC §2255. He never claimed actual innocence of the underlying crime he pleaded guilty to. Nor did he assert rights newly recognized by the Supreme Court in Descamps v. U.S., 133 S. Ct. 2276. Descamps is not retroactively applicable on collateral review, nor would it have bearing on Williams' sentence.
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