Mangine v. Withers, No. 18-3639 (7th Cir. 2022)
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Mangine, serving a 35- year sentence for federal drug and firearm offenses, sought post-conviction relief under 28 U.S.C. 2241, contending that the sentencing court mischaracterized him as a career offender and that the error resulted in his ineligibility for a discretionary sentence reduction he would like to pursue under 18 U.S.C. 3582(c)(2). His previous post-conviction motions under sections 2266 and 2241 had been unsuccessful. He had previously been denied a sentence reduction under 18 U.S.C. 3582(c)(2); Amendment 782 to the Guidelines, which retroactively reduced by two levels the offense level for most drug-trafficking crimes. did not change his Guidelines range as originally calculated.
The district court denied relief, concluding that such ineligibility does not amount to a miscarriage of justice—thereby precluding Mangine from satisfying the conditions for pursuing post-conviction relief under section 2241. The Seventh Circuit affirmed. Mangine could no longer be designated as a career offender in light of intervening Supreme Court decisions but that is not what drove his sentence. Even without the designation, his Guidelines range would have been 360 months to life. Mangine did not receive “far greater punishment than that usually meted out for an otherwise similarly situated individual who had committed the same offense.” He did not suffer a miscarriage of justice.
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