United States v. Worthington, No. 21-2218 (8th Cir. 2024)
Annotate this CaseIn 1996, Duane D. Worthington was charged with several crimes related to a robbery he committed in Iowa. The government sought enhanced penalties due to his past convictions for robbery and attempted robbery, which they argued constituted “serious violent felonies” under federal law. Worthington pled guilty to all four counts and received a sentence of 425 months in prison. Years later, the Supreme Court ruled that increasing a statutory minimum sentence under the Armed Career Criminal Act (ACCA)’s residual clause violated the Fifth Amendment’s due process clause. Following this ruling, Worthington sought to challenge his sentence, arguing that his past convictions no longer qualified as violent felonies under the ACCA. The district court vacated his sentence and ordered a resentencing hearing. The court determined that Worthington was a "career offender" under the United States Sentencing Guidelines (U.S.S.G.) and imposed a new sentence of 420 months. Worthington appealed, arguing that the district court erred in calculating his advisory sentencing range. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision, holding that the district court was bound by the appellate court's prior decision that denied Worthington authorization to challenge his career offender status. Therefore, the district court did not err by refusing to recalculate Worthington’s advisory sentencing range under the newer version of the Guidelines.
Court Description: [Grasz, Author, with Smith, Chief Judge, and Wollman, Circuit Judge] Criminal case - Sentencing. This court granted authorization for defendant to challenge his ACCA sentence on the basis of Johnson v. United States, 576 U.S. 591 (2015), but it denied authorization for him to challenge his career offender Guidelines sentence, or his conviction or sentence for the offense under 18 U.S.C. Sec. 924. Before the district court, defendant asked the court to grant his 2255 motion, vacate his sentence and schedule a hearing for him to be sentenced without application of the Armed Career Criminal Act. At sentencing the district court considered defendant as a career offender for purposes of calculating his Guidelines range; the court sentenced defendant to 420 months, five months less than his previous sentence, and defendant appeals. The district court properly followed this court's judgment and mandate by not relitigating the issue of whether defendant was a career offender for purposes of sentencing and by refusing to recalculate defendant's advisory guidelines range under the newer version of the Guidelines.
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