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 that involved defendant's 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. Ct. further found that Begay and Chambers applied retroactively and rejected state's claim that instant sentencing error did not warrant any habeas relief where defendant's enhanced sentence was within authorized 20-year statutory maximum for his crime.