United States v. Bradley Walker, 80 F.4th 880

Defendant Bradley Walker shot a man, led police on a high-speed chase, and was arrested with a pistol, ammunition, and bags of methamphetamine and fentanyl; officers administered naloxone when he became lethargic.
Walker pleaded guilty to being a felon in possession of a firearm under 18 U.S.C. § 922(g).
The district court found Walker an armed career criminal under 18 U.S.C. § 924(e), placed him in Criminal History Category VI, and calculated a Guidelines range of 188–235 months.
The court varied upward, principally based on Walker's violent and extensive criminal history (including a prior shooting to the head), and imposed 300 months’ imprisonment plus five years’ supervised release.
On appeal Walker challenged (1) the court’s § 924(e) findings (jury vs judge determination), (2) the substantive reasonableness of his sentence, and (3) inconsistencies between the oral sentence and written judgment regarding supervised-release conditions.
The court affirmed the sentence in all respects except it vacated the portion of the judgment imposing the standard supervised-release conditions and one special condition (disclosure to prescribing physicians) and remanded for limited resentencing to reconcile oral and written conditions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 924(e) enhancement required a jury finding that prior felonies occurred on different “occasions”	Precedent allows the court to decide such predicate-occurrence facts; Walker’s priors were on separate occasions	Walker argued a jury must find the "occasions" element (preserved for appeal)	Foreclosed by circuit precedent; judge’s finding upheld; facts show priors months/years apart
Whether the 300‑month sentence was substantively unreasonable	Sentence reasonable given violent criminal history and danger posed	Sentence excessive and substantively unreasonable	Affirmed—district court did not abuse discretion and permissibly weighed dangerousness heavily
Whether written judgment imposed supervised‑release conditions not orally pronounced (standard conditions and a disclosure special condition)	Written judgment’s conditions reflect enforcement needs; some conditions relate to orally pronounced special conditions	Walker argued oral pronouncement controls; written conditions were not announced and thus should not bind him	Vacated the portion imposing the standard conditions and the third special condition; remanded for limited resentencing to determine which conditions, if any, are encompassed by the oral sentence; defendant may object

United States v. Robinson, 43 F.4th 892 (8th Cir. 2022) (circuit precedent regarding judicial findings for ACCA predicate timing)
United States v. Cruz, 38 F.4th 729 (8th Cir. 2022) (standard of review for substantive reasonableness of sentence)
United States v. Foster, 514 F.3d 821 (8th Cir. 2008) (oral sentence controls when written judgment conflicts)
United States v. Glass, 720 F.2d 21 (8th Cir. 1983) (the oral pronouncement is the judgment of the court)
United States v. Tramp, 30 F.3d 1035 (8th Cir. 1994) (oral pronouncement constitutes the court's judgment)