Roundtree v. United States, No. 16-3298 (8th Cir. 2018)
Annotate this CaseOn remand, the district court concluded that petitioner was procedurally barred from asserting a claim under Burrage v. United States, 134 S. Ct. 881, 892 (2014), denied relief, and issued a certificate of appealability. The Supreme Court in Burrage held that, if the drug distributed by the defendant is not an independently sufficient cause of the victim’s death or serious bodily injury, a defendant cannot be held liable under the penalty enhancement of 21 U.S.C. 814(b)(1)(C) unless such use is a but-for cause of the death or injury. The Eighth Circuit affirmed, holding that an incorrect jury instruction did not result in prejudice excusing petitioner's procedural default under Burrage. In this case, no reasonable jury would have found that the heroin provided by petitioner was a contributing factor but not the but-for-cause of the victim's fatal overdose.
Court Description: Loken, Author, with Wollman and Murphy, Circuit Judges] Prisoner case - Habeas. For the court's prior opinion remanding the matter for a hearing on Roundtree's claim that trial counsel was ineffective for failing to advise that he faced a potential mandatory life sentence, see Roundtree v. U.S., 751 F.3d 923 (8th Cir. 2014). On remand, Roundtree sought to add an issue regarding the jury instructions, citing Burrage v. U.S., 134 S.Ct. 881 (2014). The district court court denied the request, and on appeal, this court remanded. On remand, the district court concluded Roundtree was procedurally barred from raising the Burrage claim. Based on the uncontradicted medical testimony in the case (that absent the incremental effect of the heroin distributed by defendant the victim would have lived), the incorrect jury instruction did not result in prejudice which would excuse Roundtree's procedural default, as no reasonable jury would have found that the heroin provided by Roundtree was a contributing factor but not the but-for-cause of the victim's fatal overdose.
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