UNITED STATES OF AMERICA v. ROY CHRISTOPHER WEST - Articles

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UNITED STATES OF AMERICA v. ROY CHRISTOPHER WEST

Posted by: Julia Wilburn on Jun 9, 2023

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ON BRIEF: Jessica Currie, UNITED STATES ATTORNEY’S OFFICE, Detroit, Michigan, for Appellant.

Attorneys 2: Craig A. Daly, CRAIG A. DALY, P.C., Royal Oak, Michigan, for Appellee.

Judge(s): BOGGS, GIBBONS, and McKEAGUE, Circuit Judges

Court Appealed: Appealed from United States District Court for the Eastern District of Michigan at Detroit

GIBBONS, Circuit Judge. Roy West was convicted for his participation in a murder-for-hire conspiracy and sentenced to life in prison. After his direct appeals and 28 U.S.C. § 2255 motion failed, West sought compassionate release under 18 U.S.C. § 3582. In that motion, he argued for the first time that his sentence violated Apprendi v. New Jersey, 530 U.S. 466 (2000). He claimed that the jury instructions given at his trial did not sufficiently require the jury to find that death resulted from the conspiracy — a necessary finding for the court to impose a life sentence for the crime. The district court found that the Apprendi error and West’s rehabilitation constituted “extraordinary and compelling reasons” to reduce his sentence and granted West compassionate release after 17 years’ imprisonment. 18 U.S.C. § 3582(c)(1)(A). On appeal, the government argues that the judgment of the district court should be reversed because it improperly used compassionate release as a vehicle for second or successive § 2255 motions. We agree and reverse.

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