Watkins v. United States District Court for the Central District of Illinois, No. 18-2967 (7th Cir. 2022)Annotate this Case
In 2004, Watkins was convicted of possessing crack cocaine with intent to distribute. He received a mandatory life sentence based on three prior convictions for “felony drug offenses.” After multiple unsuccessful collateral attacks, Watkins filed this 28 U.S.C. 2241 petition, citing the Supreme Court’s 2016 “Mathis” decision and arguing that two of his prior convictions did not qualify as predicate felony drug offenses under 21 U.S.C. 841(b)(1)(A), so his enhanced sentence was unlawful. Following enactment of the First Step Act of 2018, Watkins applied for relief under that statute, was resentenced to time served, and was released from prison. He is currently serving a reduced term of supervised release.
The Seventh Circuit remanded with instructions to dismiss the 2241 petition as moot. Watkins can only speculate that Watkins might benefit from a decision on the merits; the mere possibility that a decision might influence the court’s determination on remand concerning his term of supervised release is not enough to keep the case alive. Intervening case law, combined with the government’s concession, should be more than enough to make clear in any future section 3583(e) proceedings that Watkins was not properly subject to a mandatory life sentence.