Yobarri Eason v. United States, 912 F.3d 1122

In 2008 Eason pleaded guilty to distributing cocaine base and to possessing a firearm as an armed career criminal (ACCA) and received concurrent 220‑month sentences; he did not appeal.
The PSR identified prior convictions (aggravated robbery, simple robbery, second‑degree assault) that triggered the ACCA enhancement for the firearm count.
In 2014 Eason unsuccessfully moved under § 2255 to vacate the firearm sentence based on Descamps; the district court held the motion time‑barred.
In 2016 the Eighth Circuit authorized a successive § 2255 motion based on Johnson; the district court denied relief under the concurrent sentence doctrine because vacating the ACCA enhancement would not reduce Eason’s total time to serve.
Eason argued the district court erred because vacating the ACCA sentence could cause adverse future consequences (higher supervised‑release revocation exposure) or trigger full resentencing under the “sentencing package” doctrine.
The Eighth Circuit reviewed de novo and affirmed, holding speculative future consequences and the sentencing‑package theory did not defeat the concurrent sentence doctrine.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the concurrent sentence doctrine bars review of a successive § 2255 challenge to an ACCA enhancement on a concurrent firearm sentence	Eason: doctrine should not bar review because vacating ACCA could reduce future supervised‑release revocation exposure and might require full resentencing under the sentencing‑package doctrine	Government/District Court: successful challenge would not reduce Eason’s total time now; alleged future harms are speculative and within Eason’s control; sentencing‑package claim is inapplicable	Court affirmed denial: concurrent sentence doctrine applies; speculative collateral consequences insufficient; sentencing‑package argument rejected

Descamps v. United States, 570 U.S. 254 (2013) (construction of predicate‑offense categorical approach)
Johnson v. United States, 576 U.S. 591 (2015) (invalidating ACCA residual clause)
Rutledge v. United States, 517 U.S. 292 (1996) (special assessment creates prejudice sufficient for § 2255 review of concurrent convictions)
Benton v. Maryland, 395 U.S. 784 (1969) (double jeopardy and concurrent convictions context)
United States v. Olunloyo, 10 F.3d 578 (8th Cir. 1993) (concurrent sentence doctrine explained)
United States v. Holmes, 620 F.3d 836 (8th Cir. 2010) (discussion of Rutledge and prejudice for concurrent convictions)
United States v. Bradley, 644 F.3d 1213 (11th Cir. 2011) (concurrent sentence doctrine applied when relief would not reduce time to serve)
United States v. Darnell, 545 F.2d 595 (8th Cir. 1976) (rejecting speculative future criminality as basis to deny doctrine application)