Cisneros v. United States

Background

A person called the petitioner asked the Court to review a decision from the United States Court of Appeals for the Ninth Circuit. The petitioner also moved to proceed in forma pauperis — that is, to continue without paying court fees — and the Court granted that motion. The lower-court decision involved the Armed Career Criminal Act’s “residual clause,” which was at issue in the Court’s later decision in Johnson v. United States.

Reasoning

The Court followed the Solicitor General’s recommendation and had held the petition while Johnson was pending. After Johnson, the Court granted review, vacated the Ninth Circuit’s judgment, and remanded the case for further consideration in light of Johnson’s holding that the residual clause is void for vagueness. The Supreme Court’s order does not resolve whether the petitioner should get relief; it tells the appeals court to reconsider the case under the new rule.

Real world impact

Court of Appeals judges in the Ninth Circuit must reexamine cases that relied on the residual clause, which could change sentences or convictions for people whose prior crimes were counted under that clause. The order is a procedural step tied to Johnson and does not itself award or deny relief; the appeals court must decide whether any change in law requires changing the result.

Dissents or concurrances

Justice Alito wrote a short opinion agreeing with holding, vacating, and remanding. He emphasized that the Court did not decide who should win and that the appeals court should not assume the Supreme Court views the petitioner as entitled to relief.