United States v. Robert Watkins
692 F. App'x 307
| 8th Cir. | 2017Background
- Watkins originally sentenced under ACCA enhancement; Johnson v. United States held ACCA residual clause unconstitutional, prompting Watkins' §2255 vacatur and resentencing.
- At resentencing Watkins had served over ten years of a fifteen-year sentence and was in a halfway house; his time already exceeded the newly calculated statutory maximum (ten years) after removing the ACCA enhancement.
- The district court sentenced Watkins to "time served" for the prison term and imposed one year of supervised release (statutory maximum available was three years).
- Watkins asked the district court to rephrase the judgment as "ten years, credit for time served" to aid BOP computations for any future supervised-release violation; the court declined.
- On appeal Watkins argued (1) the wording "time served" might prevent BOP credit for over-served time and thus render the sentence illegal for exceeding the statutory maximum, and (2) the one-year supervised release term was substantively unreasonable.
- Watkins did not raise the sentence-legality argument below, so the court reviewed that claim for plain error; the supervised-release challenge was reviewed for abuse of discretion/substantive reasonableness.
Issues
| Issue | Plaintiff's Argument (Watkins) | Defendant's Argument (Gov't) | Held |
|---|---|---|---|
| Whether "time served" wording made the sentence illegal or prejudicial by preventing BOP credit for over-served time | "Time served" might preclude BOP from crediting the over-served prison term, effectively exceeding the newly calculated statutory maximum | BOP computation issues are speculative and not binding on the district court at sentencing | No plain error; wording was not legally erroneous and BOP calculation concerns are not a sentencing-law basis to vacate |
| Whether imposition of one year supervised release was substantively unreasonable | Extra time in prison and halfway-house placement accomplished rehabilitative aims; supervised release would be punitive/redundant | District court reasonably weighed §3553(a) factors and found supervised release appropriate to assist transition to community | No abuse of discretion; one year was reasonable within district court's broad sentencing latitude |
| Whether supervised release can be satisfied by time served before resentencing | Watkins: prior confinement/halfway-house time fulfilled supervised-release purposes | Court/Gov't: by law supervised release begins upon release from confinement; prior custody does not count | Pre-release confinement does not satisfy supervised release requirements |
| Standard of review for unpreserved legality claim | Watkins: (implicit) the error affected substantial rights and warrants correction | Gov't: claim forfeited; reviewed only for plain error | Court applied plain-error test and found no reversible error |
Key Cases Cited
- Johnson v. United States, 135 S. Ct. 2551 (2015) (invalidated ACCA residual clause as unconstitutionally vague)
- Gall v. United States, 552 U.S. 38 (2007) (sentencing reasonableness review and abuse-of-discretion standard)
- United States v. Mosby, 719 F.3d 925 (8th Cir. 2013) (supervised release begins when inmate is released from confinement)
- United States v. Chavarria-Ortiz, 828 F.3d 668 (8th Cir. 2016) (distinguishing waiver and forfeiture; context for plain-error review of sentencing objections)
- United States v. Johnson, 529 U.S. 53 (2000) (describing supervised release's rehabilitative purpose)
- United States v. Olano, 507 U.S. 725 (1993) (plain-error doctrine elements)
- United States v. Rush-Richardson, 574 F.3d 906 (8th Cir. 2009) (application of plain-error standard)