Smith v. United States
Headline: Criminal case sent back as the Court vacates the lower ruling and orders reconsideration in light of Johnson, potentially affecting people whose cases relied on the ACCA residual clause.
Holding: The Court granted review, vacated the Sixth Circuit’s judgment, and sent the case back for reconsideration in light of Johnson, without deciding whether the defendant will ultimately get relief.
- Sends lower-court cases back to reconsider convictions tied to the ACCA residual clause.
- Creates potential for relief for defendants if the Court finds the residual clause void.
- Order is not a final merits decision; outcomes may change on further review.
Summary
Background
A person who challenged a Sixth Circuit ruling involving the Armed Career Criminal Act asked the Supreme Court to review the case and to proceed without paying court fees. The Court granted that request and agreed to consider the petition while another major case, Johnson v. United States, was pending.
Reasoning
Instead of deciding the merits, the Court vacated the judgment below and sent the case back to the Court of Appeals for reconsideration in light of the Johnson decision. The opinion does not resolve whether the petitioner will ultimately get relief; it directs the lower court to reexamine the case under the new guidance from Johnson.
Real world impact
On remand, the Court of Appeals must reconsider the case with Johnson’s ruling in mind. That could lead to relief for people whose convictions or sentences depended on the ACCA’s so-called residual clause, but this outcome is not automatic and depends on further proceedings. The Supreme Court’s action is procedural, not a final determination on guilt or sentence.
Dissents or concurrances
Justice Alito wrote a short concurrence emphasizing that the Court’s decision to hold, vacate, and remand does not indicate whether the petitioner deserves relief and that lower courts should not assume the Supreme Court’s action resolves entitlement to relief.
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