Melvin v. United States
Headline: Court vacates and remands a federal sentence ruling in light of a major vagueness decision, asking the Fourth Circuit to re-evaluate whether the ACCA residual clause affected the sentence.
Holding: The Court granted the petition, vacated the lower court’s judgment, and remanded the case to the Fourth Circuit for reconsideration in light of Johnson v. United States.
- Requires lower courts to re-evaluate sentences affected by ACCA’s residual clause.
- May make some federal sentences shorter if the clause no longer counts as a crime.
- Order is procedural and does not itself change anyone’s sentence.
Summary
Background
An individual who had been sentenced under the federal Armed Career Criminal Act asked the Supreme Court to review the Fourth Circuit’s decision. The petitioner also moved to proceed without paying fees. The Supreme Court had held this and other similar petitions while it considered Johnson v. United States, and after Johnson the Court granted review, vacated the judgment below, and sent the case back to the Fourth Circuit for reconsideration in light of that decision.
Reasoning
The core issue was whether the ACCA’s so-called residual clause is too vague to be used to increase sentences. The Supreme Court did not resolve that question here on the merits. Instead, following Johnson, the Court used a procedural GVR order — it granted review, vacated the lower-court judgment, and remanded for further consideration. That approach tells the lower court to apply Johnson’s reasoning and decide whether the petitioner actually gets relief.
Real world impact
People sentenced under the ACCA may see their cases re-examined by appeals courts, which must now decide if the new vagueness rule changes outcomes. The order itself does not change anyone’s sentence; it only sends the case back for fresh consideration. Some prisoners may win shorter sentences, while others may get no relief if procedural rules or other facts prevent it. Many similar cases that were held pending Johnson will follow the same path.
Dissents or concurrances
Justice Alito wrote a short concurrence emphasizing that the Court’s grant-vacate-remand does not mean the petitioner is entitled to relief. He noted the Court did not distinguish cases where relief would follow Johnson from cases where procedural barriers would block relief, and he advised the Fourth Circuit not to read the order as a decision on the merits.
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