Narvaez v. U.S.

Dist. Ct. erred in denying defendant's habeas petition challenging application of career offender enhancement on his sentence following his bank robbery conviction where said enhancement was based on two prior escape convictions involving his failure to return to confinement. Under Begay and Chambers, defendant's prior convictions did not qualify as violent felonies for purposes of applying career offender enhancement, and Ct. further found that Begay and Chambers applied retroactively to defendant's case, so as to entitle him to new sentencing hearing without consideration of career offender enhancement.