Johnson v. United States

2005-04-04

Headline: Court rules one-year clock starts when a state court vacates a prior conviction, but only if the defendant promptly sought that vacatur after the federal judgment, limiting late federal sentence challenges.

Holding: The Court held that the one-year limitations period under 28 U.S.C. §2255 begins when a petitioner receives notice of a state-court vacatur, provided the petitioner diligently sought that vacatur after the federal judgment.

Real World Impact:

Starts one-year clock from notice of state vacatur if petitioner acted promptly.
Requires defendants to pursue state vacatur promptly after federal judgment to preserve relief.
Long delays can defeat federal challenges even after state vacatur.

Topics: federal sentence challenges, statute of limitations, state conviction vacatur, habeas petitions

Summary

Background

Robert Johnson, a federal prisoner, received a longer sentence in 1994 because two 1989 Georgia convictions were used to enhance his federal term. After his federal judgment, Johnson later asked a Georgia court to vacate several prior convictions; the state court reversed those convictions in 1998. He then sought to reopen his federal sentence, but federal courts rejected his request as untimely under the new one-year deadline in 28 U.S.C. §2255 created by AEDPA.

Reasoning

The Court asked when the one-year limit in §2255(4) begins if a state vacatur removes the prior conviction that led to a federal enhancement. The majority agreed that the fact of a state vacatur can trigger the one-year period, but only if the prisoner acted with due diligence in seeking that vacatur after the federal court entered judgment. The Court chose the federal judgment date as the point after which the prisoner must act diligently to seek state relief, and it rejected arguments that would either start the clock earlier or dispense with any diligence requirement. Applying that rule, the Court found Johnson waited too long before pursuing the state vacatur and so his federal petition was untimely.

Real world impact

The decision resolves a split among appeals courts about timing. Prisoners who successfully get a state vacatur can start a fresh one-year window, but only if they promptly tried to obtain the vacatur after the federal judgment. Because Johnson delayed years before seeking state relief, he lost the chance for federal resentencing, showing that long delays can bar federal attacks on enhanced sentences.