Travis Raymond v. United States, 933 F.3d 988

Background

In 2014 Raymond pleaded guilty to methamphetamine distribution and being a felon in possession of a firearm; the district court applied the ACCA and imposed concurrent 15-year sentences (ACCA mandatory minimum on the firearm count).
Raymond appealed; this court initially affirmed. After Johnson v. United States, Raymond filed a pro se §2255 petition arguing the ACCA enhancement no longer applied.
The district court agreed the residual-clause-based ACCA enhancement no longer applied to three predicate convictions and thus Raymond did not qualify for ACCA, but denied §2255 relief because the 15-year sentence could still be within the Guidelines range (no "complete miscarriage of justice").
Raymond later, with counsel, moved under Fed. R. Civ. P. 60(b)(6) to reopen; the district court denied the motion for the same reason but granted a certificate of appealability.
The Eighth Circuit reviewed only the Rule 60(b)(6) denial for abuse of discretion, concluded the district court applied the wrong standard (treating a constitutional sentencing error like an ordinary Guidelines error), and vacated and remanded for reconsideration in light of intervening authority (Quarles) and other Rule 60(b)(6) factors.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Raymond is entitled to relief from his sentence because the ACCA enhancement is invalid under Johnson	Raymond: Johnson voided the ACCA residual clause; his Minnesota predicates no longer qualify, so his sentence was imposed in violation of the Constitution	Government: Even without ACCA, the same 15-year sentence could have been imposed under the Guidelines; later Quarles may revive the ACCA applicability to Minnesota burglary	Court: District court erred by treating the error as non-constitutional harmlessness; a constitutional sentencing error requires harmlessness analysis; vacated and remanded to reconsider merits in light of Quarles and Rule 60(b)(6) factors
Whether the district court abused its discretion in denying Rule 60(b)(6) relief	Raymond: The Rule 60(b)(6) motion sought reconsideration of a constitutional error; extraordinary circumstances exist because sentence was imposed in violation of the Constitution	Government: The sentencing error was harmless because the same sentence could be reimposed	Held: Denial was an abuse of discretion because the court applied the wrong standard and failed to consider prejudice from the constitutional error (including supervised-release implications)
Effect of Quarles on whether Minnesota burglary qualifies as an ACCA predicate	Raymond: Quarles does not necessarily make Minnesota third-degree burglary an ACCA violent felony; statutory text and Minnesota law may exclude it	Government: Quarles broadened burglary scope and may revive ACCA applicability, undermining Raymond's §2255 success	Held: Court remanded for district court to reconsider the ACCA-predicate question in light of Quarles

Key Cases Cited

Johnson v. United States, 135 S. Ct. 2551 (holding ACCA residual clause void for vagueness)
Quarles v. United States, 139 S. Ct. 1872 (construing burglary offense for ACCA purposes)
Sun Bear v. United States, 644 F.3d 700 (8th Cir.) (discussing limits on §2255 for Guidelines errors)
Cravens v. United States, 894 F.3d 891 (8th Cir.) (constitutional sentencing error is cognizable under §2255 and requires harmlessness analysis)
Buck v. Davis, 137 S. Ct. 759 (discussing extraordinary circumstances standard for Rule 60(b)(6))
Gonzalez v. Crosby, 545 U.S. 524 (Rule 60(b) and habeas limits)
Addonizio v. United States, 442 U.S. 178 (miscarriage of justice standard for collateral relief)
Hill v. United States, 368 U.S. 424 (same)