District of Columbia Court of Appeals
Wilson v. United States
August 13, 2026
Summary
The court held that the District of Columbia's violent-crime sentence-enhancement statute does not apply when the two prior convictions occurred during the same proceeding on the same day, even if the underlying offenses were committed at different times. Because the enhancement was improperly imposed, Wilson's sentence was illegal and could be corrected at any time under Rule 35(a). The court vacated the sentence and remanded for resentencing, declining to reach Wilson's ineffective-assistance and sentence-reduction claims.