Steve Wright, Jr. v. United States
902 F.3d 868
8th Cir.2018Background
- Steve L. Wright, Jr. was convicted in 2006 of 14 federal counts (drug, firearms, and aiding/abetting witness murder). Some offenses occurred while he was a juvenile; others occurred after he turned 18.
- Count 7 (aiding and abetting the murder of a witness) carried a statutory mandatory life sentence; the district court originally imposed life plus 110 years overall, including guideline-based life for grouped drug counts and consecutive § 924(c) terms (including convictions for conduct pre-18).
- After related Supreme Court decisions (Graham, Miller, Montgomery), Wright filed a successive § 2255 motion; the government conceded Count 7’s mandatory life violated Miller because the murder occurred when Wright was a juvenile.
- The district court vacated the life term on Count 7, resentenced Wright to 15 years on that count, and denied relief on other counts; Wright appealed, arguing he was entitled to broader resentencing under Graham/Miller.
- The Eighth Circuit affirmed: it held Wright was not entitled to successive collateral relief on Count 1 or the consecutive term-of-years § 924(c) convictions, and that vacating Count 7 did not require a comprehensive resentencing of all counts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller/Graham require resentencing on Count 1 (conspiracy spanning pre- and post-18 conduct) | Wright: Count 1 involved juvenile conduct; Miller/Graham require consideration of youth so resentencing is required | Government: Count 1 was sentenced under advisory Guidelines; Miller’s ban on mandatory LWOP for juveniles doesn’t mandate relief here | Denied — no successive relief; advisory sentencing allowed consideration of youth and Miller’s procedural protections do not extend to Count 1’s adult sentencing context |
| Whether consecutive lengthy term-of-years sentences for pre-18 § 924(c) convictions (Counts 4,6,9) violate Graham as an "effective life" | Wright: The stacked terms produced an effective life sentence for juvenile conduct, invoking Graham | Government: Graham does not clearly extend to lengthy non-homicide terms; issue unsettled | Denied as moot/harmless — even if error, aggregate life + 60 years equals same as existing life sentence, so no relief granted |
| Whether vacating Count 7’s life sentence required a comprehensive resentencing of the entire sentence package | Wright: Eighth Amendment errors on multiple counts tainted whole sentence; district court should hold full resentencing | Government: District court has discretion; only Count 7 required resentencing | Denied — district court did not abuse discretion in limiting resentencing to Count 7 after upholding other counts |
| Whether successive § 2255 authorization properly denied as to other claims | Wright: Miller/Montgomery entitle him to broader relief | Government: Claims fall outside the new substantive rule or are procedural and non-retroactive | Denied — successive habeas relief not warranted for Count 1 or the § 924(c) terms |
Key Cases Cited
- Graham v. Florida, 560 U.S. 48 (juveniles convicted of nonhomicide crimes cannot be sentenced to life without parole)
- Miller v. Alabama, 567 U.S. 460 (mandatory life without parole for juvenile homicide offenders unconstitutional; requires individualized sentencing considering youth)
- Montgomery v. Louisiana, 136 S. Ct. 718 (Miller’s substantive rule is retroactive on collateral review)
- United States v. Wright, 536 F.3d 819 (8th Cir.) (direct appeal affirming convictions and sentence)
- United States v. Jefferson, 816 F.3d 1016 (8th Cir. 2016) (district court resentenced under advisory guidelines applying Miller)
- United States v. Bour, 804 F.3d 880 (7th Cir. 2015) (life and life plus lengthy terms can be equivalent for harmlessness analysis)