Ragland v. United States, No. 14-3748 (8th Cir. 2015)
Annotate this CaseThe district court denied Ragland’s petition under 28 U.S.C. 2255 for relief from his conviction and sentence for distribution of heroin resulting in death (21 U.S.C. § 841(a)(1) and (b)(1)(C)), which has a mandatory sentence of 20 years to life. On remand, the government conceded it could not prove but-for causation and that the Supreme Court’s decision in Burrage applied retroactively, but argued the district court lacked authority to grant relief because the enhanced sentence Ragland received did not exceed the maximum statutory sentence without application of the enhancement. The district court concluded that Ragland’s claim was not cognizable under section 2255, denied relief, and denied a Certificate of Appealability. The Eighth Circuit vacated and remanded with instructions to enter judgment on the lesser included offense of distribution of heroin and resentence Ragland. Ragland’s claim under Burrage was a challenge to the validity of his conviction for distribution of heroin resulting in death, and therefore was cognizable under section 2255.
Court Description: Per Curiam - Before Riley, Chief Judge, and Melloy and Benton, Circuit Judges] Prisoner case - habeas. For the court's prior opinion in Ragland's habeas, see Ragland v. U.S., 756 F.3d 597 (8th Cir. 2014), where the court remanded the matter for further consideration in light of Burrage v. United States, 134 S. Ct 881 (2014). Ragland's claim under Burrage is a challenge to the validity of his conviction for distribution of heroin resulting in death and is cognizable under Section 2255; as a result, the court grants Ragland's request for a certificate of appealability, vacates his conviction for distribution of heroin resulting in death and remands the matter with instructions to the district court to enter judgment on the lesser included offense of distribution of heroin and resentence Ragland for that offense. [ April 28, 2015
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