Gooden v. United States
Headline: Order vacates and remands a Fourth Circuit sentence, sending the case back for reconsideration after the Court’s ruling on the ACCA 'residual clause' vagueness, affecting people sentenced under that law.
Holding: In granting the petition, the Court vacated the Fourth Circuit’s judgment and remanded for reconsideration in light of Johnson v. United States, without expressing a view on entitlement to relief.
- Requires the appeals court to reconsider ACCA-based sentences under Johnson.
- May allow some people sentenced under the ACCA residual clause to seek new relief.
Summary
Background
A person who had his sentence reviewed by the United States Court of Appeals for the Fourth Circuit asked the Supreme Court to take the case and to proceed without paying court fees. The Court granted leave to proceed in forma pauperis, granted the petition for review, and then vacated the lower court’s judgment and sent the case back for further consideration. Justice Kagan did not take part in deciding this motion and petition.
Reasoning
The Court acted in light of its decision in Johnson v. United States (2015), which addressed the meaning of the Armed Career Criminal Act’s so-called "residual clause." By vacating and remanding, the Supreme Court instructed the Fourth Circuit to reconsider the case under the legal guidance provided by Johnson. The order does not itself decide whether the person is entitled to a new outcome; it sends the matter back so the appeals court can apply Johnson’s reasoning to the record.
Real world impact
The practical effect is that people whose sentences relied on the ACCA residual clause will have their appeals reconsidered by the courts below in light of Johnson. This ruling is procedural, not a final decision on relief, so some individuals may get new relief while others may not depending on the appeals court’s review. The Supreme Court’s order does not signal a final position about any individual’s entitlement to a new sentence or other relief.
Dissents or concurrances
Justice Alito wrote a short concurrence explaining that the Court held many similar cases pending Johnson and emphasized that the remand does not indicate any view on whether this individual should receive relief.
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