Jean Cazy v. United States, 16-16045

Jean Cazy was convicted by jury of multiple offenses including Hobbs Act robbery conspiracy and § 924(c) firearm offenses and sentenced in 2014 (248 months, later reduced to 211 months) plus six $100 special assessments ($600 total).
Cazy filed a § 2255 motion claiming, among other things (Claim 6), that Johnson undermined the use of Hobbs Act conspiracy as a predicate for his § 924(c) conviction.
The district court denied the § 2255 motion but, "out of an abundance of caution," waived the $100 special assessment for the conviction tied to Claim 6, reducing his overall assessment to $500.
The Eleventh Circuit granted a COA on (1) whether the district court erred by reducing the special assessment by $100, and (2) whether Claim 6 was properly denied under the concurrent sentence doctrine.
The panel reviewed legal issues de novo and considered statutory limits on a district court's authority to modify sentences and mandatory monetary assessments under 18 U.S.C. § 3013.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court could waive $100 special assessment post-sentencing	Cazy sought relief tied to Claim 6; district court waived assessment for that count	Government defended mandatory assessment and limits on post-sentencing modification	Court held district court lacked authority to waive mandatory $100 assessment; waiver vacated
Whether concurrent-sentence doctrine bars review of Claim 6 after concurrent sentences imposed	Cazy argued Claim 6 should be considered; he would not get benefit under concurrent-sentence doctrine	Government argued concurrent-sentence doctrine precludes relief because sentences are concurrent	Court held concurrent-sentence doctrine inapplicable because monetary assessment attaches to each conviction, creating adverse collateral consequences; Claim 6 denial vacated and remanded

Rutledge v. United States, 517 U.S. 292 (mandatory special assessment and collateral consequences of multiple convictions)
Pinkus v. United States, 436 U.S. 293 (separate convictions with separate penalties are not fully concurrent)
United States v. Phillips, 597 F.3d 1190 (limits on district court authority to modify sentences)
United States v. Puentes, 803 F.3d 597 (district court lacked authority to eliminate mandatory monetary penalty)
Mamone v. United States, 559 F.3d 1209 (standard of review for § 2255 legal questions)
United States v. Bradley, 644 F.3d 1213 (concurrent sentence doctrine and adverse collateral consequences)
In re Williams, 826 F.3d 1351 (applying concurrent-sentence doctrine where no showing of collateral consequences)
In re Chance, 831 F.3d 1335 (monetary penalties distinguish cases and create adverse collateral consequences)