Davis v. United States
Headline: Cases tied to the Armed Career Criminal Act’s vague "residual clause" are sent back to lower courts as the Court vacated judgments and remanded for reconsideration after its Johnson decision.
Holding: The Court granted leave to proceed without fees, granted review, vacated the appeals court’s judgment, and remanded the case to the Fifth Circuit for reconsideration in light of Johnson v. United States.
- Sends convictions tied to the ACCA residual clause back to appeals courts for reconsideration.
- Allows defendants to seek relief based on Johnson’s ruling that the residual clause is vague.
- Lower courts must decide whether procedural issues block relief despite Johnson’s ruling.
Summary
Background
A person who was sentenced under federal law challenged a sentence tied to the Armed Career Criminal Act’s so-called residual clause. The filer asked the Supreme Court to review the Fifth Circuit’s decision, sought permission to proceed without paying fees, and the Court held the petition pending its decision in Johnson v. United States.
Reasoning
The central practical question was whether decisions that relied on the ACCA residual clause should be revisited in light of Johnson, which addressed whether that clause is unconstitutionally vague. The Court allowed the person to proceed without fees, granted review, vacated the appeals court’s judgment, and sent the case back to the Fifth Circuit to reconsider the matter in light of Johnson. The Court’s action did not resolve whether the person actually gets relief on the merits.
Real world impact
As a result, appeals courts must reexamine convictions and sentences that depended on the ACCA residual clause in light of Johnson’s ruling. Lower courts will decide whether procedural issues prevent relief or whether convictions must be changed. This ruling is a procedural step, not a final decision on guilt or sentence, and outcomes can still vary based on later lower-court rulings.
Dissents or concurrances
Justice Alito wrote separately to explain that the Court held many cases pending Johnson and warned that vacating and remanding does not express any view about whether an individual is entitled to relief.
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