Howard v. United States
Headline: Court vacates and returns a sentence-related appeals decision for reconsideration after ruling that a key federal sentencing rule is unconstitutionally vague, potentially affecting people with prior convictions.
Holding: In a grant-vacate-remand order, the Court sent the case back to the appeals court for further review in light of Johnson, concluding a key part of the federal sentencing law is void for vagueness.
- Sends cases back to appeals courts to reconsider sentences tied to the voided sentencing clause.
- May reduce enhanced sentences for people with certain prior convictions.
- Leaves final relief uncertain until appeals courts re-evaluate individual cases.
Summary
Background
An individual asked the Supreme Court to review a decision from the Eighth Circuit and also requested permission to proceed without paying court fees. The Supreme Court granted that request and the petition, then vacated the appeals court judgment and sent the case back for further consideration in light of a recent decision called Johnson v. United States. The Solicitor General had recommended holding many similar cases pending that decision.
Reasoning
The central question was whether a part of the federal Armed Career Criminal Act — the so-called "residual clause" that can increase a sentence based on prior crimes — is too vague to be applied. The Court acted by vacating the lower court judgment and remanding for reconsideration after Johnson, which the Court has treated as holding that the residual clause is void for vagueness. The Supreme Court’s order does not itself decide whether this particular person must get relief; it directs the appeals court to reconsider the case under the new rule.
Real world impact
Appeals courts must re-examine cases where sentences were raised because of the residual clause. People previously given longer sentences under that clause may get new review, but relief is not automatic: the appeals court must decide whether the person is entitled to a reduced sentence. This decision is procedural and depends on how each appeals court applies the Supreme Court’s new ruling to individual records.
Dissents or concurrances
Justice Alito wrote a short concurrence stressing that the Court’s order to vacate and remand does not indicate whether the petitioner will ultimately receive relief, and that the Court did not separate cases where relief is automatic from those with procedural bars.
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