Daniel Lee Sappington v. United States

Daniel Sappington, in this post-conviction proceeding, seeks to vacate his sentence for failure of the sentencing judge to make an explicit finding that he would not have benefited from treatment under the Federal Youth Corrections Act, 18 U.S.C. § 5005 et seq. The petitioner, who was twenty-one years old at the time of conviction and sentence, was sentenced as an adult. The District Court denied relief stating that the “no benefit” finding was implicit in the imposition of the adult sentence.

The Federal Youth Corrections Act requires an explicit “no benefit” finding. Dorszynski v. United…