Eason v. United States, No. 17-3299 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit affirmed the district court's application of the concurrent sentence doctrine to petitioner and denial of 28 U.S.C. 2255 relief. The court held that sentencing petitioner as an armed career criminal on the firearm count had no impact on his advisory guidelines range for the drug trafficking charge, and his 220 month sentence was 40 months above the Armed Career Criminal Act's mandatory 180-month minimum. In this case, petitioner did not appeal his convictions and sentences for concurrent 220 month prison terms, and the district court did not err in denying the successive habeas motion under the concurrent sentence doctrine. Furthermore, the court noted that the collateral consequences petitioner claimed was more than highly speculative where they were entirely within his control to avoid.
Court Description: Loken, Author, with Smith, Chief Judge, and Gruender, Circuit Judge] Prisoner case - Habeas. While this court gave Eason leave to file a successive habeas challenging his 220-month sentence on a firearm count based on Johnson, he did not challenge his concurrent 220-month sentence for distributing crack, and the district court did not err in denying the successive habeas motion under the concurrent sentence doctrine; an argument that failure to address his sentence on the firearm count might have future adverse collateral consequences is rejected as any future adverse consequences are entirely within Eason's control to avoid.
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