United States v. Williams, No. 19-2235 (8th Cir. 2020)
Annotate this Case
The Eighth Circuit affirmed defendant's 190 month sentence imposed under the Armed Career Criminal Act (ACCA) after he pleaded guilty to possessing a firearm as a felon. The court held that revising a sentencing recommendation for a legitimate reason during a sentencing hearing is not prosecutorial vindictiveness and there was no prosecutorial vindictiveness in this case. Regardless, defendant cannot show that his substantial rights were affected where the district court considered the sentencing factors at length, stressing those important to the sentence.
The court also held that the district court did not err by deciding that defendant's four prior serious drug offenses were "committed on occasions different from one another." Furthermore, defendant's argument that this determination is a fact to be decided by a jury, not the judge, is foreclosed by precedent. Therefore, defendant's Sixth Amendment rights were not violated.
Court Description: [Benton, Author, with Smith, Chief Judge, and Kobes, Circuit Judge] Criminal case - Sentencing. The government reversed its sentencing recommendation for a valid reason and its action did not constitute prosecutorial vindictiveness; defendant failed to show the sentence the court imposed was vindictive; the district court did not err by deciding, without a jury, that defendant's four prior serious drug offenses were committed on occasions different from one another and that determination did not violate defendant's Sixth Amendment rights.
The court issued a subsequent related opinion or order on May 13, 2022.
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.