Johnson v. Manis

Background

A case from the United States Court of Appeals for the Fourth Circuit was brought to the Supreme Court for review. The Supreme Court granted the petition for review, vacated the judgment below, and instructed the Fourth Circuit to reconsider the case in light of Montgomery v. Louisiana. The opinion notes that this petition was one of many cases the Court held pending the Montgomery decision.

Reasoning

The Court’s action was procedural: it ordered further consideration by the lower court rather than resolving the core merits questions itself. Justice Thomas, joined by Justice Alito, emphasized that the Court’s decision to grant, vacate, and remand does not decide whether the person seeking relief is actually entitled to retroactive relief. Thomas listed possible issues for the lower courts to consider, including whether a state law ground bars relief, whether the person forfeited or waived rights (for example by a plea agreement), and whether the sentence qualifies as a mandatory life-without-parole sentence. Other Justices, including Alito, Sotomayor, and Ginsburg, separately noted their agreement with the grant-vacate-remand action and cited a related case, Adams v. Alabama.

Real world impact

The decision sends the case back to the Fourth Circuit for further review; it does not provide a final victory or denial for the person who sought relief. The lower court must now examine the listed issues in light of Montgomery, and its conclusions could still permit or deny relief. Because many cases were held pending Montgomery, similar cases will also proceed through lower courts for further consideration.

Dissents or concurrances

No dissenting opinion is shown; several Justices wrote brief concurrences stressing that the GVR order is not a merits decision and listing questions the lower court should address.