United States v. Holroyd, No. 20-3083 (D.C. Cir. 2024)
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The case revolves around Wayne Holroyd, who pleaded guilty to conspiracy to distribute and possess with intent to distribute more than 280 grams of crack cocaine. After his plea but before his sentencing, Congress amended the "safety valve" provision of the statute used to compute Holroyd's sentence, expanding the eligibility of a drug offender to be sentenced without regard to the statutory mandatory minimum. However, the district court sentenced Holroyd to the statutory minimum of 120 months' imprisonment. Holroyd argued that his counsel should have contended that he was eligible for sentencing without regard to the statutory minimum under the recently revised safety valve provision.
The district court sentenced Holroyd to the mandatory minimum of 120 months' imprisonment. Holroyd's counsel did not move for reconsideration. Holroyd contended that his counsel was constitutionally ineffective in representing him at sentencing because counsel failed to give the correct interpretation to the safety valve provision. He argued that his two past convictions did not exclude him from the safety valve under the provision because the word "and" between subparagraphs must be read conjunctively so that only a defendant who has convictions satisfying all subparagraphs cumulatively is ineligible.
The United States Court of Appeals for the District of Columbia Circuit affirmed the district court's sentence. The court held that Holroyd's counsel's decision not to argue at sentencing or to move for reconsideration on the basis of Holroyd's eligibility for the safety valve was not deficient representation. The court noted that the Supreme Court recently adopted a different construction of the safety valve provision, which held that a defendant satisfies the criminal-history requirement only when he does not meet any of the disqualifying criteria. As Holroyd had a 6-point criminal history based on two previous 3-point offenses, he did not satisfy the criteria and was therefore ineligible for the safety valve.
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