Lorenzo Roundtree v. John Caraway

EASTERBROOK, Circuit Judge.

Lorenzo Roundtree was sentenced to life in prison for selling heroin that led to a user's death. 21 U.S.C. § 841 (b)(1)(C). Seven years later the Supreme Court held that a judge must tell a jury that the death-resulting condition is satisfied only if the drug was a but-for cause of the fatality; a contributing cause is not enough. Burrage v. United States , 571 U.S. 204 , 134 S.Ct. 881 , 187 L.Ed.2d 715 (2014). The charge to the jury at Roundtree's trial did not satisfy Burrage , and he filed collateral attacks on his sentence in both the Northern District of Iowa…