Sixth Circuit: United States v. Clarence Goodwin


No procedural error in review of sentence, as the retroactive element of the law only reduced the minimum term, not the guidelines range, and the court adequately recited that it had considered the petitioner's arguments. The reliance on the career-offender sentencing consideration to reach the guidelines range under the new calculation didn't offend Due Process.

Substantively, bootstrapping a challenge to the career-offender calculations to the retroactive changes would be unfair to those who were sentenced only under the former.  

DISSENT:

Career-offender guidelines are tied to the maximum sentence, which, although not made retroactive here, would be different under the new statute; court's explanations did not demonstrate that it understood the complexity of the deft's claims.

United States v. Clarence Goodwin