United States v. Oaks
2011 U.S. App. LEXIS 24799
6th Cir.2011Background
- Oaks pleaded guilty to felon-in-possession and was sentenced to 120 months and five years of supervised release.
- On appeal, the Sixth Circuit initially affirmed the sentence; Supreme Court later vacated and remanded for reconsideration after Chambers v. United States.
- The remand directed the district court to determine the type of custody facility and security level of the Carter County Sheriff's custody at Oaks's escape.
- District court found Oaks escaped from a nonsecure courtroom while in law-enforcement custody during a court appearance on felony charges.
- The question presented was whether escape from nonsecure custody constitutes a violent felony for ACCA sentencing purposes.
- The majority held that such an escape is not a violent felony; the court remanded for resentencing consistent with that view.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether escape from nonsecure custody is a violent felony | Oaks argues escape from custody is violent under Chambers. | Government argues nonsecure custody escape is not violent; Chambers controls. | Escape from nonsecure custody is not a violent felony |
| What constitutes the custody/security context for the escape | Courtroom escape while in law-enforcement custody should be treated as secure custody. | Rush of factors indicates nonsecure setting; security status of courtroom matters. | Nonsecure custody escape; courtroom not secure; not a violent felony |
| Effect of Chambers on this case | Chambers supports treating this as violent due to risk to apprehender. | Chambers data and USSC report show nonsecure escapes rarely violent. | Chambers supports nonviolence finding; district must follow this framework |
| Remand outcome | Oaks should be resentenced with ACCA factors reconsidered under nonviolent finding. | Remand for resentencing consistent with majority's interpretation. | Remand for resentencing consistent with holding that escape from nonsecure custody is not violent |
Key Cases Cited
- Chambers v. United States, 555 U.S. 122 (2009) (violent felony analysis under ACCA; uses risk framework)
- United States v. Oaks, 554 F.3d 1087 (6th Cir. 2009) (remand on custody type for Oaks's escape)