Hill v. Masters, No. 15-5188 (6th Cir. 2016)
Annotate this CaseIn 2000, Hill was arrested, following an undercover investigation into drug-trafficking activities between Baltimore and Charleston. Hill pleaded guilty to conspiracy to distribute more than 100 grams of heroin, 21 U.S.C. 846, 841(a), and was sentenced under the then-mandatory 2001 Sentencing Guidelines Manual. Hill had two prior felony convictions, a controlled-substance offense and second-degree assault, and was sentenced as a career offender (USSG 4B1.1) to 300 months of imprisonment, which was affirmed. Hill has brought several challenges to his sentence. In 2014, Hill filed a section 2241 habeas corpus petition, citing the Supreme Court’s 2013 Descamps decision and the Fourth Circuit’s subsequent Royal decision, to argue that his “second-degree assault conviction no longer qualifies as a ‘crime of violence,” and that he is “serving an erroneous career offender sentence" that makes him “categorically ineligible” for retroactive amendments to the guidelines that could reduce his sentence by several years. Finding section 2241 inapposite because Hill did not claim to be “actually innocent,” the district court denied Hill’s motion. The Sixth Circuit reversed, stating that section 2241 petitions may be used by prisoners who were sentenced under the mandatory guidelines regime; who are foreclosed from filing a successive petition under section 2255; and when a subsequent, retroactive change in statutory interpretation by the Supreme Court reveals that a previous conviction is not a predicate offense for a career-offender enhancement.
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