Coney v. Pastrana
Headline: Court vacates and sends back a defendant’s sentence case for reconsideration after a ruling that a key federal sentencing clause was unconstitutionally vague, affecting others sentenced under that rule.
Holding: The Court granted review, vacated the Eleventh Circuit’s judgment, and remanded the case for reconsideration in light of Johnson v. United States, without deciding entitlement to relief.
- Sends cases back for reconsideration after a ruling that a federal sentencing clause is void for vagueness.
- Leaves open who will actually get relief; courts must decide case by case.
- Affects people sentenced under the ACCA’s residual clause pending further review.
Summary
Background
A person who appealed a sentence tied to the Armed Career Criminal Act asked the Court to review the Eleventh Circuit’s decision. The Court allowed the person to proceed without paying fees and agreed to consider the case. It then vacated the lower court’s judgment and sent the case back for further consideration in light of a recent Supreme Court decision called Johnson v. United States.
Reasoning
The central question was whether the appeals court should re-evaluate the sentence now that Johnson held the ACCA’s so-called "residual clause" void for vagueness. Following the Solicitor General’s recommendation, the Court held the petition, granted review, vacated the judgment below, and remanded the case for reconsideration. The Court explicitly declined to decide here whether the person is entitled to relief.
Real world impact
Lower courts must reconsider cases where sentences depended on the ACCA’s residual clause, so some defendants could see changed outcomes. This order is procedural: it sends cases back for review rather than granting or denying relief itself. The final result for any person will depend on how the appeals court applies Johnson to the facts of each case.
Dissents or concurrances
Justice Alito wrote separately agreeing with the grant-vacate-remand but emphasized that the Court’s disposition does not reflect any view on whether the person should receive relief.
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