Denson v. United States
Headline: A person’s appeal tied to the federal 'residual clause' is sent back to the appeals court after the Justices vacated the lower-court decision and ordered reconsideration in light of Johnson v. United States.
Holding: The Court granted the petition, allowed the person who filed it to proceed without fees, vacated the Eleventh Circuit’s judgment, and sent the case back for reconsideration in light of Johnson v. United States (2015).
- Sends the case back to the appeals court to reconsider under Johnson's rule.
- Does not itself grant relief; final outcome may still change.
- Applies Johnson's view that the ACCA residual clause is void for vagueness.
Summary
Background
A person who had asked the Supreme Court to review a decision from the United States Court of Appeals for the Eleventh Circuit sought permission to proceed without paying court fees. The Court granted that request, agreed to consider the petition, vacated the judgment below, and sent the case back to the Eleventh Circuit for further consideration in light of Johnson v. United States (2015).
Reasoning
The Court did not resolve the underlying dispute here. Instead, following the Solicitor General’s recommendation, the Court had held the petition pending the Johnson decision, and after Johnson the Court vacated the lower-court judgment and remanded so the appeals court can reexamine the case under Johnson’s guidance. Johnson addressed the status of the Armed Career Criminal Act’s so-called "residual clause," which Johnson treated as void for vagueness.
Real world impact
The Eleventh Circuit must reevaluate the earlier decision using the legal standard set out in Johnson. The Supreme Court’s order does not itself grant relief; it directs the lower court to reconsider, so the final outcome may still change for the person who asked for review. This is not a final merits ruling on entitlement to relief.
Dissents or concurrances
Justice Alito joined the grant, vacatur, and remand but emphasized that the Court’s disposition should not be read as expressing any view about whether the person ultimately deserves relief, and that the Court did not distinguish cases where relief would be available from cases where procedural obstacles might block relief.
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