United States v. Wyatt, 2012 U.S. App. LEXIS 4574

Background

Wyatt was convicted of a drug offense in the Southern District of Illinois and was later sentenced in the district as a career offender under §4B1.1 based in part on treating a walkaway escape from a halfway house as a qualifying crime of violence.
His guideline range with the career-offender designation was 262–327 months, and he received 262 months imprisonment; without that designation his base level and range would have been lower (roughly 120–150 months).
Wyatt unsuccessfully appealed his conviction and sentence on direct review (Wyatt I), and his counsel did not seek certiorari challenging that affirmation.
Wyatt challenged his sentence through multiple §2255 and §2241 petitions across different courts and circuits, with repeated recharacterizations and transfers that created a procedural maze.
Chambers and Begay later influenced Wyatt’s arguments, prompting further petitions arguing sentencing guidance misclassification; district court decisions repeatedly held that §2241 or §2255 were the proper vehicles, and transfers continued to occur.
The Seventh Circuit concluded the district court’s initial transfer was erroneous, recognized the ongoing procedural confusion, and ultimately denied Wyatt’s Petition for Rehearing and his motion to convert for successive relief; the court noted limited prospects for meaningful collateral relief and suggested executive clemency as the remaining remedy.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper vehicle for challenging career-offender status post-Chambers/Begay	Wyatt contends §2241 (via escape hatch) or other routes allow merits review of the career-offender misclassification.	United States maintains procedural restraints; §2255 or other routes are inappropriate or inadequate under the circumstances.	Procedural path for merits review is improper; relief denied on the merits via the chosen vehicle.
Whether district court or circuit transfer orders were proper or should be revisited	Wyatt argues transfers recharacterizing petitions were erroneous and that Texas district remains proper forum.	The government contends transfers were appropriate to route petitions to the proper venue.	The initial transfer order was clearly erroneous; the Seventh Circuit retained jurisdiction to address the petitions.
Impact of Christianson and priorWyatt decisions on remedy	Wyatt relies on law-of-the-case/revisitability to resolve where claims may be heard and how they should be treated.	The government resists reopening past decisions and contends appropriate procedural boundaries remain.	The Western District’s transfer decisions were not the controlling path; the court limited prospects for collateral relief consistent with Christianson.
Whether Wyatt could obtain relief given current law and posture	Chambers/Begay should entitle relief; previous cases suggest possible §2241 relief or reconsideration.	Given the sentencing guidelines context and current law, relief is unlikely through collateral channels.	Wyatt faces no viable collateral remedy at this stage; relief denied.

Key Cases Cited

United States v. Wyatt, 133 F. App'x 310 (7th Cir. 2005) (Wyatt I; walkaway escape deemed a crime of violence for career-offender purposes (with then-available circuit law).)
Wyatt v. United States, 574 F.3d 455 (7th Cir. 2009) (Wyatt II; collateral-review framework and ineffective-assistance considerations.)
Chambers v. United States, 555 U.S. 122 (U.S. 2009) (Interprets passive-felonies and tests for violent felonies in related schemes.)
Begay v. United States, 553 U.S. 137 (U.S. 2008) (Defines how to determine a crime is a violent felony based on the statute itself.)
Welch v. United States, 604 F.3d 408 (7th Cir. 2010) (Addresses savings clause limitations and collateral relief viability in similar contexts.)
Christianson v. Colt Indus. Operating Corp., 486 U.S. 800 (U.S. 1988) (Law-of-the-case and the court's power to revisit prior decisions under extraordinary circumstances.)