This morning, the Eleventh Circuit has issued Varela v. U.S., a per curiam holding that Blakely and Booker are not retroactively applicable to cases on collateral review. (For those of you who don't speak the lingo, this means roughly "People who are already in jail, and whose original appeals have all run their course, cannot get any benefit from Booker and Blakely through a petition for habeas corpus."). Some other Circuits have already so held, if I'm not mistaken. The Circuit describes this holding as mandated by the Supreme Court's decision in Schriro v. Summerlin. If you're interested in the details, Varela was a federal prisoner whose guidelines score had been increased by a non-jury finding on the amount of drugs.