United States v. Antonio Anthony Williams
705 F. App'x 160
| 4th Cir. | 2017Background
- Antonio Anthony Williams pleaded guilty to being a felon in possession of a firearm (18 U.S.C. § 922(g)(1)) and was sentenced to 51 months' imprisonment.
- The district court applied an enhanced base offense level under USSG § 2K2.1(a)(4)(A) because Williams committed the offense subsequent to a prior felony that was a crime of violence or controlled substance offense.
- The sentencing enhancement rested on prior North Carolina convictions: first-degree burglary (consolidated with robbery with a dangerous weapon).
- Williams’ counsel filed an Anders brief conceding no meritorious appeal but questioning the sentence and the effect of Johnson v. United States on the predicate-offense classification.
- The Fourth Circuit reviewed for procedural and substantive reasonableness and whether Johnson/Beckles affected the Guidelines residual clause application.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Johnson’s invalidation of ACCA’s residual clause voids the Guidelines’ residual clause for enhancement | Williams argued Johnson undermines the Guidelines residual clause and thus the enhancement | Government argued Beckles forecloses a vagueness challenge to the Guidelines residual clause | Beckles controls; Guidelines residual clause not void for vagueness, so Johnson does not help Williams |
| Whether Williams’ prior NC convictions qualify as crimes of violence for the enhancement | Williams (through counsel) questioned classification post-Johnson | Government relied on Fourth Circuit precedent that NC burglary and robbery-with-weapon qualify as violent offenses | Fourth Circuit concluded precedents foreclose challenge; convictions qualify and support the enhancement |
| Whether the district court miscalculated the Guidelines or committed procedural error at sentencing | Williams suggested possible sentencing error | Government maintained Guidelines were correctly calculated and factors considered | Court found no procedural error; Guidelines range correctly calculated and court adequately explained sentence |
| Whether the within-Guidelines 51-month sentence was substantively unreasonable under § 3553(a) | Williams argued sentence may be excessive | Government argued sentence reasonable and within Guidelines presumption | Court presumed reasonableness of within-Guidelines sentence; Williams failed to rebut presumption; sentence affirmed |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (1967) (procedures when counsel finds appeal frivolous)
- Gall v. United States, 552 U.S. 38 (2007) (standard for reviewing sentence reasonableness)
- Johnson v. United States, 135 S. Ct. 2551 (2015) (ACCA residual clause void for vagueness)
- Beckles v. United States, 137 S. Ct. 886 (2017) (Guidelines not subject to vagueness challenge under Johnson)
- United States v. Mack, 855 F.3d 581 (4th Cir. 2017) (North Carolina first-degree burglary qualifies as generic burglary for Guidelines)
- United States v. Louthian, 756 F.3d 295 (4th Cir. 2014) (presumption of reasonableness for within-Guidelines sentences)
- United States v. Montes-Flores, 736 F.3d 357 (4th Cir. 2013) (ACC A violent-felony and Guidelines crime-of-violence analyses used interchangeably)