United States v. Antonio Maldonado, 538 F. App'x 457

Maldonado was arrested after police found a firearm in his vehicle while he was on state parole; indicted federally for being a felon in possession (18 U.S.C. § 922(g)(1)).
A federal writ of habeas corpus ad prosequendum produced him into federal custody on March 22, 2012; he pleaded guilty on May 21, 2012.
At rearraignment the district court misstated the maximum penalty as 10 years; the AUSA had indicated Maldonado might qualify as an armed career criminal.
At sentencing the court determined Maldonado qualified as an armed career criminal (U.S.S.G. § 4B1.4 / 18 U.S.C. § 924(e)) and the mandatory minimum was 15 years; Maldonado declined to withdraw his plea.
Defense asked the court to (1) impose 180 months, (2) designate Texas Department of Criminal Justice as place of confinement, and (3) set the federal sentence to commence November 29, 2011 (crediting state custody time); the court adopted that wording in the judgment.
On appeal both parties agreed the district court erred: the court lacks authority to set the federal sentence commencement date or designate place of confinement—those are BOP determinations—so the sentence was vacated and remanded; conviction affirmed.

Issue	Maldonado's Argument	Government's Argument	Held
Whether the district court could set the federal sentence commencement date to November 29, 2011 (thereby crediting state custody).	Court intended to credit Maldonado for time in state custody beginning Nov. 29, 2011.	District court lacks authority to set commencement date or award credit; only BOP may calculate credit.	Court held the district court erred; only BOP (Attorney General) may compute and award pre-commencement credit; judgment vacated and remanded.
Whether district court could designate Texas Dept. of Criminal Justice as place to serve federal sentence.	Requested designation to allow concurrent service with state revocation.	Placement is BOP authority under 18 U.S.C. § 3621 and credit/commencement rules; court cannot designate.	Court agreed it lacked authority to designate place of confinement; sentence vacated.
Whether the sentence must be vacated when both parties and the court operated under the same legal error.	Argued the wording failed to effectuate court’s intent and was legally ineffectual.	Government concurred that the sentence was legally infirm and should be vacated.	Court vacated the sentence and remanded for further proceedings; conviction affirmed.
Whether the conviction itself should be disturbed.	N/A — challenge focused on sentencing mechanics.	N/A.	Conviction affirmed.

United States v. Wilson, 503 U.S. 329 (Court held that only the Attorney General, through the Bureau of Prisons, can compute credit for time served and that a district court cannot award credit by designating the commencement date of a federal sentence.)