Robert A. Mangine v. Shannon D. Withers, Warden

Petitioner in this case, Mr. Robert Mangine, is wrongfully classified as a career offender. His misclassification did not become apparent until after this Court’s decision in Mathis v. United States, 136 S. Ct. 2243 (2016), by which time Mr. Mangine had already filed his first motion under 28 U.S.C. § 2255. Because he was barred from filing a second or successive § 2255 motion, Mr. Mangine filed a habeas petition pursuant to the “savings clause” of § 2255(e). Mr. Mangine asserted that his erroneous careeroffender status deprives him of the right to seek a sentence reduction pursuant to 18 U.S.C. § 3582(c)(2) based on a retroactive amendment to the Sentencing Guidelines. The district court dismissed the petition, and a panel of the Seventh Circuit affirmed. The panel held that categorical ineligibility for a sentence reduction under § 3582(c)(2) does not constitute a “miscarriage of justice” and therefore does not warrant savings clause relief. The questions presented are: Whether and under what circumstances relief is available under § 2255(e) for federal prisoners challenging errors in their sentences; and Whether the erroneous deprivation of Petitioner’s statutory right to seek a sentence reduction under 18 U.S.C. § 3582(c)(2) constitutes a miscarriage of justice such that Petitioner may obtain relief under § 2255(e).