Kurt Harrington v. J. Ray Ormond

ROGERS, Circuit Judge.

*248 Kurt Harrington, a federal prisoner proceeding pro se, appeals the district court's judgment denying his petition for a writ of habeas corpus filed under 28 U.S.C. § 2241 and based on Burrage v. United States , 571 U.S. 204 , 134 S.Ct. 881 , 187 L.Ed.2d 715 (2014). Harrington was sentenced to life in prison for his role in a drug-distribution conspiracy that resulted in the death of another and thus implicated the "death results" penalty enhancement of 21 U.S.C. § 841 (b)(1). In Burrage , the Supreme Court held that the death-results enhancement requires that drugs…