United States v. Walter Moray Williams

Walter Moray Williams appeals his sentence under the United States Sentencing Guidelines. Williams contends that his due process rights were violated because his adult criminal sentence was enhanced due to prior juvenile adjudications at which he did not have a right to a jury trial. Williams also contends that the district court erroneously categorized his prior commitment to juvenile hall as a term of imprisonment, thereby enhancing his adult sentence. We affirm the sentence imposed by the district court.

FACTS

Williams entered a plea of guilty on October 6, 1988 for bank robbery in violation of 18 U.S.C. § 2113 (a). At the time of his sentencing, this court had invalidated the Sentencing Reform Act of 1984 and the United States Supreme Court had not yet reviewed our decision. The district court imposed two alternative sentences on Williams. The first sentence was imposed under the law applicable prior to the effective date of the Sentencing Reform Act. The second alternative sentence was imposed using the United States Sentencing Guidelines enacted pursuant to the Sentencing Reform Act.

The Supreme Court subsequently upheld the validity of the Sentencing Reform Act in…