Bryant, Jr. v. United States
24-CO-0255
| D.C. | Aug 21, 2025Background
- Bernard Bryant, Jr. was convicted of second-degree murder committed at age 20 and sentenced to 21 years to life.
- The crime occurred when Bryant fired into a crowd attacking his friend, resulting in one death; he was convicted after his first trial ended in a mistrial.
- After 24 years of incarceration, Bryant moved for sentence reduction under the Incarceration Reduction Amendment Act (IRAA).
- The trial court denied relief, finding Bryant had not shown non-dangerousness or that the interests of justice warranted a reduction.
- The appellate court found errors in the trial court's consideration of mitigating facts, Bryant's history of sexual abuse, and the weight given to his juvenile criminal history, vacating and remanding for reconsideration.
Issues
| Issue | Bryant's Argument | Government's Argument | Held |
|---|---|---|---|
| Failure to consider third-party involvement under IRAA factor nine | Attackers' role mitigated culpability | Bryant solely responsible for choosing to shoot | Trial court erred by not considering mitigating role of third parties |
| Misstatement regarding childhood sexual abuse (factor two, factor eight) | Bryant was sexually abused by a neighbor as a child | Bryant had no reported abuse and described childhood in pleasant terms | Trial court clearly erred; abuse must be considered |
| Excessive weight on teenage criminal history | Youthful offenses shouldn't bar IRAA relief; overreliance inverts IRAA's logic | Criminal history relevant, especially pre-offense violent acts | Trial court gave unsustainable weight to juvenile history contrary to IRAA's purpose |
| Weighing 2011 prison infraction and Bryant's use of "accident" to describe crime | Infraction was old/non-violent; "accident" is lay term for reckless acts | Infractions and lack of remorse showed dangerousness | Court invites reconsideration but does not rule it was error |
Key Cases Cited
- Bishop v. United States, 310 A.3d 629 (D.C. 2024) (Trial court abuses discretion under IRAA when it fails to consider relevant mitigating factors; elaborates on IRAA criteria.)
- Crater v. Oliver, 201 A.3d 582 (D.C. 2019) (Sets standard for abuse of discretion review in IRAA contexts.)
- Koonce v. United States, 993 A.2d 544 (D.C. 2010) (Defines elements of first-degree child sexual abuse.)
- In re D.W., 989 A.2d 196 (D.C. 2010) (Defines elements of second-degree child sexual abuse.)
- Henny v. United States, 321 A.3d 621 (D.C. 2024) (Clarifies requirements for findings as based on specific factual predicate in sentence review.)
- Busey v. United States, 747 A.2d 1153 (D.C. 2000) (Explains distinction between first- and second-degree murder.)