Resentencing in the Eleventh Circuit after a Taylor-Based § 2255 Vacatur: Scope, Limits, and the “One-Claim Only” Rule

1. Introduction

In United States v. Michael Shane Ragland, No. 23-12278 (11th Cir. June 24 2025) (unpublished), the Eleventh Circuit confronted a procedural labyrinth that increasingly confronts federal courts: what happens after a § 924(c) conviction is vacated in light of United States v. Taylor, 596 U.S. 845 (2022), and the inmate returns for resentencing on a still-massive robbery package? Ragland challenged virtually every facet of the district court’s response—its refusal to give him a “full” resentencing, denial of his bid to amend his second-in-time § 2255 motion, rejection of First Step Act (“FSA”) relief, and ultimate imposition of 2,072 months’ imprisonment.

The Court’s opinion, though unpublished, stitches together a coherent set of principles that now govern similar post-Taylor cases in the circuit. Most importantly it:

Re-affirms that a district court’s resentencing after partial § 2255 relief may be narrow—confined to the effects of the vacatur—so long as the judge actually holds a hearing and recalculates the package (Brown/Fowler blueprint).
Holds that because Ragland’s original 2010 sentence pre-dated the FSA, § 403’s anti-stacking amendment does not apply, even after the sentence was later vacated (United States v. Hernandez, 107 F.4th 965 (11th Cir. 2024)).
Stresses the tight jurisdictional leash on successive § 2255 motions: a prisoner authorized to raise “one claim” may not tack on others by Rule 15(c) amendment or by styling them as sentencing objections.
Clarifies that a district court can—and did—consider post-sentencing rehabilitation and the weight of mandatory § 924(c) terms (Pepper, Dean) but is free, within § 3553(a), to conclude they do not warrant a variance.

2. Summary of the Judgment

The panel (Jordan, Luck & Tjoflat, JJ.) affirmed Ragland’s amended 2,072-month sentence. The court rejected three categories of error:

Procedural Reasonableness. The resentencing satisfied Gall: the district judge recalculated the Guidelines, treated them as advisory, addressed § 3553(a), relied on no clear factual error, and explained the decision. Any possible Guidelines mis-scoring was harmless under Keene.
Denial of Rule 15(c) Amendment. Because the Eleventh Circuit had authorized only a single Taylor-based claim attacking Count 16, the district court lacked subject-matter jurisdiction to entertain new challenges to other § 924(c) counts (or to aggregate counts under Wooden). Rule 15 cannot expand jurisdiction.
Substantive Reasonableness. A within-Guidelines, below-statutory-maximum sentence—stacked though it is—“falls in the ballpark of permissible outcomes.” The district court’s heavy emphasis on deterrence and dangerousness was not an abuse of discretion.

3. Detailed Analysis

3.1 Precedents Cited and Their Influence

United States v. Taylor, 596 U.S. 845 (2022) – Triggered the vacatur of Count 16 (attempted Hobbs Act robbery no longer a “crime of violence” under § 924(c)).
United States v. Davis, 588 U.S. 445 (2019) & Johnson v. United States, 576 U.S. 591 (2015) – Earlier invalidations of residual clauses; part of the doctrinal chain rendering some § 924(c) predicates invalid.
United States v. Brown, 879 F.3d 1231 (11th Cir. 2018) – Sets the two-step § 2255 remedy framework (vacate, then choose between four remedies) and clarifies when de novo resentencing is required.
United States v. Fowler, 749 F.3d 1010 (11th Cir. 2014) – Sentencing “package” theory: on partial vacatur the court may redesign the structure to achieve original goals.
United States v. Hernandez, 107 F.4th 965 (11th Cir. 2024) – A pre-FSA sentence counts as “imposed” for § 403(b); therefore the anti-stacking amendment is unavailable on resentencing.
Dean v. United States, 581 U.S. 62 (2017) – Judges may consider § 924(c) mandatory minimums when deciding concurrent/non-stacked sentences for companion counts.
Pepper v. United States, 562 U.S. 476 (2011) – Post-sentencing rehabilitation is relevant at resentencing.
Gall v. United States, 552 U.S. 38 (2007); Keene, 470 F.3d 1347 (11th Cir. 2006) – Appellate review standards; harmless Guidelines error doctrine.
Wooden v. United States, 595 U.S. 360 (2022) – Addresses ACCA’s “occasions” clause; Ragland attempted to import its reasoning to § 924(c), but authorization was lacking.

Collectively, these cases created a clear roadmap the panel dutifully followed: the vacatur is narrow (Taylor); resentencing may be narrow yet comprehensive (Brown, Fowler); the FSA anti-stacking relief is foreclosed (Hernandez); the district judge has discretion, but not compulsion, to lower the package based on rehab or § 924(c) hammer (Dean, Pepper).

3.2 The Court’s Legal Reasoning

Jurisdictional Parameters. The panel begins with a threshold inquiry: did the district court have jurisdiction to touch issues beyond Count 16? Under 28 U.S.C. § 2244(b)(3)(A) a successive § 2255 motion needs this court’s blessing; that blessing was expressly limited to one claim. Consequently, Rule 15(c) “relation back” cannot conjure jurisdiction where none exists. This reasoning closes the door on new Taylor- or Wooden-based attacks on the remaining § 924(c) counts.
Narrow Resentencing vs. De Novo Resentencing.
• Building on Brown, the panel distinguishes between the need to hold a resentencing hearing and the scope of that hearing.
• The district court met step 1 (hearing). For step 2 (scope) the vacatur did not “undermine the sentence as a whole” nor require “significant discretion on new issues.” The judge could thus rebuild the package mostly intact, adjusting only the now-defunct Count 16.
First Step Act § 403(a) (anti-stacking). The panel deploys Hernandez: a sentence “has been imposed” the moment it is first pronounced, even if later vacated. Because Ragland’s original sentence came in 2010—eight years before the FSA—§ 403’s leniency remains out of reach. The vacatur therefore did not render the sentence “not yet imposed.”
Guidelines Analysis and Harmless Error. Assuming arguendo the court mis-tabulated criminal history points by counting a Pennsylvania robbery as “prior” rather than “relevant conduct,” the panel applies Keene: the district judge expressly said it would impose the same sentence irrespective of the small range shift. That pronouncement renders any error harmless.
Substantive Reasonableness. Echoing prior precedent, the panel enumerates markers of reasonableness: within-Guidelines, far below aggregate statutory maxima, grounded in seriousness/deterrence. Nothing in the record shows disproportion or improper weighting.

3.3 Impact on Future Litigation

This unpublished opinion nonetheless consolidates several lessons of broad practical significance:

Authorization Orders Are Jurisdictional Guardrails. Defendants who secure leave for a single Taylor claim must seek additional authorization to reach newly fashionable theories (e.g., Wooden). Rule 15 is not a loophole.
First Step Act Relief Post-Vacatur Remains Narrow. After Hernandez and now Ragland, a previously imposed pre-2018 sentence—even if partially invalidated—continues to block § 403(a) retroactivity. Circuits are split; petitioners may attempt Supreme Court review, but for now the Eleventh holds firm.
Harmless-Error Doctrine in Resentencings. District judges who clearly state—on the record—the sentence they would impose under either Guidelines calculation insulate their judgments from remand.
Practical Boundaries of Pepper & Dean. While defendants can present rehabilitation evidence and urge § 3553(a) adjustments for stacked mandatory terms, the judge’s decision not to vary is rarely reversible absent legal misapprehension.

4. Complex Concepts Simplified

§ 2255 “Successive” Motions. Think of § 2255 as allowing one “bite at the apple.” A second bite requires appellate court permission. The appellate court may grant a narrow license (here: “you may raise one Taylor claim on Count 16 only”). The district court cannot examine anything outside that license.
“Stacking” under old § 924(c). Before 2018, each additional § 924(c) count (even within the same indictment) triggered extra mandatory sentences (5 yrs then 25 yrs, etc.) that must run consecutively. The FSA softened that, but only for sentences not yet imposed by December 2018.
Guidelines “Relevant Conduct” vs. “Prior Sentence.” Points are added for crimes committed before the instant offense (prior sentence). If the conduct is part of the same scheme (relevant conduct), no extra points apply—yielding a lower criminal history score.
Harmless Guidelines Error (Keene). Even if the district court erred in scoring, an appellate court need not remand when the judge explicitly says, and the record supports, that the ultimate sentence would be unchanged.

5. Conclusion

United States v. Ragland fortifies the Eleventh Circuit’s post-Taylor jurisprudence in three principal ways. First, it cements the idea that resentencing after partial § 2255 relief may be judiciously narrow—judges are architects repairing a single crumbling beam, not rebuilding the entire edifice. Second, it underscores that a vacated pre-2018 sentence does not re-open the door to First Step Act anti-stacking relief; the original imposition date remains decisive. Third, it reiterates iron-clad jurisdictional limits on successive § 2255 motions: if it is not in the authorization order, it is not in play.

Practitioners representing inmates who have obtained Taylor-based vacaturs must therefore craft authorization applications with foresight, requesting leave for all predicate-based challenges at once. Likewise, sentencing advocates should temper expectations: post-sentencing rehabilitation and § 924(c) “hammer” arguments remain potent mitigation tools, but district judges retain broad discretion to reject them. Ragland, albeit unpublished, is a cautionary script for both sides in the continuing saga of § 924(c) upheaval.