United States v. Williams
0:14-cr-00066
| D. Minnesota | Nov 7, 2016Background
- April Fay Lewis pleaded guilty to Count One: conspiracy to distribute methamphetamine (21 U.S.C. §§ 841(a)(1), 841(b)(1)(C), 846) pursuant to a June 2, 2014 plea agreement.
- PSR calculated offense level 31, Criminal History IV, advisory guideline range 151–188 months; statutory supervised-release minimum of 3 years.
- At sentencing the Court adopted the PSR, granted departures from the Guidelines range, and sentenced Lewis to 120 months imprisonment and 3 years supervised release on June 6, 2015.
- Lewis did not appeal. She later filed a § 2255 motion (filed Aug. 31, 2016) arguing Amendment 794 to U.S.S.G. § 3B1.2 (mitigating role) would make her a minor participant and entitle her to relief.
- The Government and the Court found Amendment 794 was not made retroactive by the Sentencing Commission and that Lewis’s factual admissions (traveling to obtain multiple kilograms, responsibility for 5–15 kg, active role in transport/distribution) did not support a minor-role reduction.
- The Court denied the § 2255 motion and declined to issue a certificate of appealability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Amendment 794 warrants sentence reduction via § 2255 | Lewis contends Amendment 794 redefines mitigating-role analysis and would qualify her as a minor participant, meriting a reduced sentence | Amendment 794 is not retroactive on collateral review and Lewis’s conduct shows she was not a minor participant | Denied: Amendment 794 was not made retroactive by the Commission for § 3582(c)(2) relief and Lewis’s factual record shows she was not substantially less culpable |
| Whether § 2255 is the proper vehicle for this relief | Implied: § 2255 can be used to challenge sentence adjustments | Court: § 2255 is extraordinary, limited to constitutional/errors not correctable on direct appeal; Lewis did not show such an error | Denied: procedural bars and substantive insufficiency preclude § 2255 relief |
| Whether Lewis’s conduct supports a mitigating-role reduction under U.S.S.G. § 3B1.2 | Lewis argues she was a minor participant under the amended commentary | Court relied on guilty-plea admissions (5–15 kg, procurement and distribution activities) and PSR findings showing active, beneficial participation | Denied: factual record precludes finding she was substantially less culpable than average participant |
| Whether to grant a certificate of appealability | Lewis seeks appellate review | Court: no substantial showing of denial of constitutional right; issues not debatable among reasonable jurists | Denied: COA refused |
Key Cases Cited
- Davis v. United States, 417 U.S. 333 (U.S. 1974) (§ 2255 relief reserved for fundamental defects causing miscarriage of justice)
- Apfel v. United States, 97 F.3d 1074 (8th Cir. 1996) (§ 2255 is extraordinary relief; limited scope)
- Sun Bear v. United States, 644 F.3d 700 (8th Cir. 2011) (§ 2255 covers jurisdictional and constitutional errors; scope severely limited)
- United States v. Thomas, 775 F.3d 982 (8th Cir. 2014) (§ 3582(c)(1)/(2) reduction available when Commission lowers the applicable guideline range)
- United States v. Quintero-Leyva, 823 F.3d 519 (9th Cir. 2016) (Amendment 794 applies retroactively on direct appeal)
- Kingsberry v. United States, 202 F.3d 1030 (8th Cir. 2000) (evidentiary hearing required on § 2255 unless records show relief is unavailable)
- Williams v. United States, 452 F.3d 1009 (8th Cir. 2006) (certificate of appealability standards)
- Cox v. Norris, 133 F.3d 565 (8th Cir. 1997) (standards for COA: issues must be debatable among reasonable jurists)