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Two FBI agents shot, and Melvin Williams’s gun count stands
The panel said the challenge could not undo a conviction under 18 U.S.C. § 924(c) because the jury still had to find Williams gave the command to shoot. That made the error harmless on collateral review.
A federal appeals court in the Third Circuit has put Melvin Williams’s gun conviction back in place after he tried to erase it through postconviction review. Williams had joined a conspiracy to rob drug dealers at gunpoint, and when two FBI special agents approached the car, he ordered his co-conspirators to shoot. Both agents were hit.
The district court had granted Williams relief under 28 U.S.C. § 2255, the federal law prisoners use to challenge convictions after trial. The Third Circuit reversed that order and sent the case back.
Why the conviction survived
The panel said the lower court applied the wrong harmless-error standard when it vacated the conviction. Williams’s challenge turned on the fact that some of the charged offenses could no longer serve as valid predicates for the gun count, but the judges said that did not end the inquiry.
What mattered, the court said, was that the jury still had to weigh the evidence that Williams gave the order to shoot and that the order led to FBI agents being wounded. On collateral review, that meant Williams had not shown the kind of error that would justify wiping out the conviction.
What changes for Williams
The ruling is not precedential, but it restores the conviction for now and returns the case to the district court for further proceedings. For Williams, the practical effect is immediate: the gun count he had knocked out is alive again.
For readers, the broader lesson is a narrow one. Postconviction review is not a second trial, even in a case built around violence against federal law enforcement. The Third Circuit said this record did not support the kind of undoing Williams wanted.