La Cruz v. United States
Headline: Vacated and remanded a criminal-sentencing appeal in light of Johnson, sending the Fifth Circuit back to reconsider challenges to the Armed Career Criminal Act’s vague "residual clause".
Holding:
- Sends the Fifth Circuit back to reconsider the case in light of Johnson.
- Requires lower courts to re-evaluate sentences tied to the ACCA residual clause.
- Does not itself grant or deny relief to the petitioner.
Summary
Background
A petitioner asked the Court to review a decision from the U.S. Court of Appeals for the Fifth Circuit. The dispute concerns the Armed Career Criminal Act’s so-called "residual clause," which the Supreme Court addressed in Johnson v. United States. The petitioner moved to proceed in forma pauperis, and the Court considered the petition alongside many similar cases while Johnson was pending.
Reasoning
The Court granted the petition, vacated the judgment below, and sent the case back to the Fifth Circuit for further consideration in light of the Court’s decision in Johnson. The Supreme Court’s action does not itself resolve whether the petitioner deserves relief; instead, it directs the lower court to reexamine the case now that Johnson has clarified that the residual clause is void for vagueness.
Real world impact
Lower courts must re-evaluate cases that relied on the Armed Career Criminal Act’s residual clause, which could change outcomes for people sentenced under that law. This order is procedural: it asks the appeals court to reconsider the specific case given Johnson’s ruling, and it does not represent a final, nationwide determination about individual entitlement to relief.
Dissents or concurrances
Justice Alito wrote separately to emphasize that the Court followed the Solicitor General’s recommendation to hold and then to vacate and remand many cases pending Johnson, and that this disposition does not signal any view on whether the petitioner should receive relief.
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