William Young v. B. Antonelli, 982 F.3d 914

Victim Dana Parks died after using crack and heroin she purchased from William Young; Young possessed crack when arrested and pled guilty in 2002 to drug conspiracy charges.
At sentencing the district court applied the Sentencing Guidelines’ "death results" enhancement (U.S.S.G. § 2D1.1(a)(1) as then in effect), producing a total offense level of 40 and a 360-month sentence.
Young filed multiple unsuccessful § 2255 motions and then sought relief under 28 U.S.C. § 2241, arguing Burrage v. United States altered the legal standard for the “death results” enhancement.
The district court dismissed Young’s § 2241 petition for lack of jurisdiction, concluding Burrage had not previously been applied to the Guidelines and thus Young’s Wheeler-based savings-clause claim was premature.
The Warden conceded that if Burrage applies to the Guidelines, Burrage would be retroactive on collateral review.
The Fourth Circuit agreed that the district court’s prematurity ruling was defensible at the time, but on appeal held Burrage’s statutory interpretation does apply to the pre-Booker Sentencing Guidelines and vacated and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Young may invoke the § 2255 savings clause via § 2241 under Wheeler (prong 2) by relying on Burrage	Burrage’s but‑for interpretation of the § 841(b)(1) "death results" enhancement applies equally to the parallel Guidelines provision, so Wheeler’s second prong is satisfied	Burrage addressed a statute, not the Guidelines; because Burrage had not been applied to the Guidelines, Wheeler’s prong 2 is not met and § 2241 is unavailable	Initially dismissal was not unreasonable; on appeal the Court holds Burrage does apply to pre‑Booker § 2D1.1(a)(1), so Young’s § 2241 claim proceeds (vacated and remanded)
Whether Burrage’s but‑for causation rule governs the mandatory (pre‑Booker) Sentencing Guidelines “death results” enhancement	Burrage’s statutory interpretation parallels and should control the Guidelines’ identical enhancement language	Burrage is limited to § 841(b)(1) and does not automatically extend to Guidelines language	Court holds Burrage does apply to the pre‑Booker § 2D1.1(a)(1) enhancement and so governs the enhancement’s causation requirement

Burrage v. United States, 571 U.S. 204 (2014) (statutory "death results" enhancement requires but‑for causation)
United States v. Wheeler, 886 F.3d 415 (4th Cir. 2018) (four‑part Wheeler test for invoking § 2255 savings clause via § 2241)
Lester v. Flournoy, 909 F.3d 708 (4th Cir. 2018) (applying savings‑clause principles to Guidelines‑based sentence challenges)
United States v. Booker, 543 U.S. 220 (2005) (made Sentencing Guidelines advisory; distinguishes pre‑Booker mandatory Guidelines)
In re Hubbard, 825 F.3d 225 (4th Cir. 2016) (applied statutory rule to Guidelines in pre‑Booker context)
Chambers v. United States, 555 U.S. 122 (2009) (example of Supreme Court statutory interpretation affecting collateral review outcomes)