Chandler v. United States
Headline: People sentenced under the federal Armed Career Criminal Act get a fresh review as the Court granted review, vacated the judgment, and sent the case back to the appeals court after Johnson clarified a key legal clause.
Holding: The Court granted the petition, vacated the Ninth Circuit judgment, and remanded for further consideration in light of Johnson v. United States.
- Sends the case back to the appeals court to re-evaluate the sentence under ACCA.
- Requires courts to reconsider other cases affected by the ACCA residual clause ruling.
- Clarifies that this order does not indicate whether the defendant deserves relief.
Summary
Background
A person asked the Supreme Court to review a Ninth Circuit decision about a sentence tied to the federal Armed Career Criminal Act (ACCA). The Court had held this petition and many others while it considered Johnson v. United States. After Johnson issued its ruling, the Court granted the petition, vacated the lower-court judgment, and returned the case to the Ninth Circuit for further consideration in light of Johnson.
Reasoning
The core legal question concerns the ACCA’s so-called "residual clause" and whether that clause is void for vagueness. The Court’s order does not resolve the underlying facts of this particular case. Instead, because Johnson announced a new rule about the residual clause, the Court directed the appeals court to reexamine the case under that decision. The Court’s action reflects a procedural step to ensure the lower court applies the new legal rule.
Real world impact
On remand, the Ninth Circuit must reconsider whether the prior sentence still stands now that Johnson addressed the residual clause. That reconsideration could change outcomes for people sentenced under the ACCA, but this order itself is not a final decision on whether any individual deserves relief. The Court explicitly cautioned that its grant-and-remand does not signal a view about the petitioner’s entitlement to relief.
Dissents or concurrances
Justice Alito concurred in the grant, vacate, and remand, noting the Solicitor General’s recommendation and stressing that the Court did not decide whether the petitioner ultimately should receive relief.
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