United States v. Barraza, No. 19-2718 (8th Cir. 2020)
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Defendant was convicted of kidnapping Maria Eloiza and her five-year-old son, resulting in the deaths of both. Defendant was 16-years-old at the time he committed the offense, and the district court sentenced him to the statutorily mandated term of life imprisonment. The Supreme Court subsequently held in Miller v. Alabama, 567 U.S. 460, 465 (2012), that a mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment's prohibition on cruel and unusual punishments. Based on Miller, the district court granted defendant's motion to vacate, set aside, or correct his sentence under 28 U.S.C. 2255. After the district court sentenced defendant to 50 years' imprisonment, defendant appealed.
The Eighth Circuit affirmed, holding that the district court did not clearly err in finding defendant competent to proceed with resentencing. In this case, the district court was entitled to base its competency determination on the BOP doctor's psychological evaluation concluding that defendant had been restored to competency. The court also held that the district court did not plainly err by calculating an advisory Guidelines range of life imprisonment under USSG 2A1.1; the district court considered the 18 U.S.C. 3553(a) sentencing factors, including defendant's youth; and defendant's sentence, a downward variance from the Guidelines range of life, was not substantively unreasonable.
Court Description: [Smith, Author, with Benton and Kobes, Circuit Judges] Criminal case - Criminal law. Barraza was sentenced to statutorily mandated terms of life imprisonment for two kidnappings resulting in death he committed at age 16; the district court granted his Section 2255 motion under Miller v. Alabama and ordered resenentcing; on resentencing, the court imposed a 50-year sentence. Barraza appeals. Held: the district court did not clearly err in determining Barraza was competent to proceed with resentencing; the court was entitled to base its competency determination on the Bureau of Prison's doctor's psychological evaluation of Barraza, which concluded he had been restored to competency; the district court did not plainly err in calculating an advisory Guidelines range of life imprisonment under Guidelines Sec. 2A1.1; the district court analyzed the 3553(a) factors, thereby satisfying Miller's procedural requirement that the court consider the defendant's youth and its attendant characteristics before imposing sentence, and the 50-year sentence, a downward variance from the Guidelines range of life, was not substantively unreasonable.
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