Raymond v. United States, No. 18-2349 (8th Cir. 2019)
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The Eighth Circuit vacated the district court's denial of petitioner's motion for relief under Federal Rule of Civil Procedure 60(b)(6). In this case, the district court determined that petitioner's sentence imposed on his firearm count was based on the Armed Career Criminal Act's unconstitutionally vague residual clause.
The court held that the district court's application of the incorrect standard was a legal error that amounted to an abuse of discretion. Furthermore, because the error was a constitutional one, petitioner was entitled to relief because the error was not harmless. Therefore, the sentencing error identified by the district court would prejudice petitioner, entitling him to relief under 28 U.S.C. 2255 and potentially entitling him to relief under Rule 60(b)(6). The panel remanded for further consideration under Quarles v. U.S., 139 S. Ct. 1872 (2019).
Court Description: {Kelly, Author, with Loken and Erickson, Circuit Judges] Prisoner case - Habeas. The error in Raymond's sentence was a constitutional one since the district court determined that the sentence imposed on his firearm count was based on the ACCA's unconstitutionally vague residual clause; the mere fact that the district court could have imposed the same term of imprisonment without the ACCA enhancement does not make the error harmless; the sentencing error identified by the district court would prejudice Raymond, entitling him to relief under Section 2255; the matter is remanded to the district court for further consideration under Quarles v. U.S., 139 S. Ct. 1872 (2019 and, if necessary, consideration of other factors affecting the court's Rule 60(b)(6) ruling in the matter.
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