United States v. Ritchison, No. 17-1238 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed the district court's vacatur of defendant's 15-year sentence and resentence to a 10-year term of imprisonment following Johnson v. United States, 135 S. Ct. 2551 (2015), and Welch v. United States, 136 S. Ct. 1257 (2016). The court held that, under these circumstances, an appropriate correction to the sentence was to enforce the parties' binding agreement under the terms of the original Federal Rule of Criminal Procedure 11(c)(1)(C), which specifically contemplated the possibility that defendant's criminal history might not trigger the enhanced penalties of the Armed Career Criminal Act (ACCA). The court declined to apply contract principles to plea agreements and rejected defendant's alternative contention of mutual mistake. Even if the parties' binding agreement was based in part on a mutual mistake, the district court did not err by enforcing it. Finally, the district court did not abuse its discretion by considering the 18 U.S.C. 3553(a) factors.
Court Description: Kelly, Author, with Benton, Shepherd, Circuit Judges] Criminal case - Sentencing. Where defendant's motion to vacate was granted under Johnson because his two prior burglary convictions no longer qualified as ACCA predicate offenses, the district court did not err in imposing the 10-year sentence the parties had agreed to under the terms of the original Rule 11(c)(1)(C) plea agreement in the event the ACCA did not apply; the district court had accepted the agreement, which contained the alternative sentences stipulated to by the parties, and there is no provision in the rules that allows the court to reject or modify the agreement, absent fraud on the court; under the circumstances presented, an appropriate correction to the sentence was to enforce the parties' binding agreement, which specifically contemplated the possibility that defendant's criminal history might not trigger the enhanced penalties provided by the ACCA; the doctrine of mutual mistake is not applicable in the context of plea agreements, and even if it was, the court did not err in enforcing the agreement; the district court did not abuse its discretion in weighing and considering the 3553(a) factors in resentencing defendant. [ April 03, 2018
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