Gray v. United States, No. 15-3223 (8th Cir. 2016)
Annotate this CaseMovant pleaded guilty to, and was sentenced for, a crime that the stipulated facts in the plea agreement did not support. After the district court corrected the statute of conviction but left movant's sentence intact, he appealed. It is undisputed that movant was convicted and sentenced under the wrong statutory subsection. Therefore, the district court correctly held that movant's guilty plea was involuntary and unknowing. The court agreed with the district court that the government has carried its burden in showing that the error was harmless. Had movant gone to trial on the original indictment, he would have been exposed to a minimum of 15 years' imprisonment. Movant acknowledged that his decision to plead guilty was because the information presented a better deal than the original indictment. Although the district court correctly determined that movant's conviction for a more severe crime than the information supported was a prejudicial constitutional error, the district court incorrectly concluded that the harm did not entitle movant to resentencing. A resentencing hearing will enable the district court to fully and accurately address all relevant sentencing factors. Accordingly, movant is entitled to be resentenced under the correct statute.
Court Description: Smith, Author, with Gruender and Benton, Circuit Judges] Prisoner case - Habeas. Gray was convicted and sentenced under the wrong statutory subsection (21 U.S.C. Sec.841(b)(1)(B) rather than 21 U.S.C. Sec. 841(b)(1)(C)), and this made his guilty plea involuntary and unknowing; however the error was harmless as Gray pleaded guilty to an offense with a higher sentencing exposure, and it is only logical to assume that he would have pleaded guilty to the correct charge, which carried a lower sentencing exposure; rather than correcting the error in this Section 2255 proceeding, the district court should resentence defendant and allow him to fully and accurately address all relevant sentencing factors; remanded for further proceedings.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.