Williams led a violent home invasion robbery in July 2018 at the Nebraska home of Michael Robertson and Jessica Brandon, where the group stole marijuana and cash while yelling "LPD! LPD! LPD!" to simulate a police raid. Eight gunshots were fired during the second night's robbery, killing Brandon. Williams was originally sentenced to 660 months on murder and robbery charges, but the Supreme Court's 2022 Taylor decision invalidated the murder conviction because robbery is not a crime of violence under federal law.
Circuit Judge Roger Loken wrote that the sentencing package doctrine properly applied even though Williams argued the remaining robbery counts were "interdependent" because they were grouped together under sentencing guidelines. "There is nothing in the Court's articulation of the doctrine suggesting that the individual counts of conviction in a multicount aggregate sentence must not be 'interdependent' to qualify for application of the doctrine," Loken explained, noting the district court "carefully limiting the aggregate sentence on remand to be within the modified advisory guidelines range."
The Eighth Circuit initially vacated Williams' conviction and remanded for resentencing in 2023 after finding the case appropriate for the sentencing package doctrine. On remand, U.S. District Judge John Gerrard imposed consecutive 222-month sentences on each robbery count, explaining the crimes occurred on "two distinct and different" nights and warranted consecutive punishment.
The decision reinforces the Eighth Circuit's broad application of the sentencing package doctrine, rejecting limitations adopted by other circuits that would bar its use when counts are grouped under guidelines calculations. Williams' challenge highlights ongoing circuit splits over when courts can reconfigure sentences after appellate reversals of related convictions.