Langford v. United States, No. 19-3541 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit concluded that the district court did not err in denying petitioner's motion to vacate, set aside or correct his life sentences. The court concluded that, for purposes of 18 U.S.C. 3559(c)(1), his Iowa convictions for robbery and first-degree robbery were serious violent felonies under the section's enumerated-offense clause. In this case, petitioner cannot show that at the time of sentencing, the district court necessarily relied on section 3559's residual clause in ruling that the aggravated robbery conviction and first-degree robbery conviction were serious violent felonies. Therefore, the district court properly refused to vacate the mandatory life sentence under section 3559.
Court Description: [Benton, Author, with Gruender and Stras, Circuit Judges] Prisoner case - Habeas. The district court did not err in denying Langford's motion to vacate, set aside or correct his life sentences; for purposes of 18 U.S.C. Sec. 3559(c)(1), his Iowa convictions for robbery and first-degree robbery were serious violent felonies under the section's enumerated-offense clause.
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