United States v. Dante Williams
Split Score
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Case Summary
Disposition
Affirmed
After the Supreme Court’s decision in United States v. Taylor required vacatur of Williams’s § 924(j) conviction, the district court resentenced him on the remaining two Hobbs Act robbery counts, imposing consecutive 222-month terms under the sentencing-package doctrine. Williams argued that the doctrine was misapplied and that the sentence was procedurally and substantively unreasonable. The Eighth Circuit rejected those arguments and affirmed, reiterating that the sentencing-package doctrine applies even where the surviving counts were grouped under the Guidelines.
Circuit Split Identified
Legal Issue
Whether the sentencing-package doctrine permits a district court to restructure sentences on the remaining counts when one count in a multicount conviction is vacated, even though the remaining counts were grouped together (or otherwise ‘interdependent’) under the Sentencing Guidelines and were originally sentenced concurrently.
Circuit Positions
Sentencing-package doctrine applies even when surviving counts were grouped/interdependent; district court may reconfigure sentences on those counts.
Sentencing-package doctrine does NOT apply if the surviving counts were grouped/interdependent; resentencing on those counts is limited to the original terms.
Conflict Summary
The Eighth Circuit holds that the sentencing-package doctrine still applies in these circumstances, allowing the district court to increase individual sentences on the surviving counts so long as the new aggregate sentence remains lawful. In contrast, the First and Third Circuits have declined to apply the doctrine where the surviving counts were grouped or interdependent, reasoning that the original grouping precludes re-packaging after one count is vacated.