Bell v. United States
Headline: Granting review, the Court vacated and remanded a criminal sentence for reconsideration after declaring the Armed Career Criminal Act’s residual clause void for vagueness, prompting many similar cases to be re-examined.
Holding: The Court granted review, vacated the lower-court judgment, and remanded the case to the Sixth Circuit for reconsideration in light of Johnson’s holding that the Armed Career Criminal Act’s residual clause is void for vagueness.
- Forces courts to re-examine convictions tied to the Act’s residual clause.
- May give relief to people sentenced under that clause, depending on procedure.
- Clarifies this order does not itself determine who deserves relief.
Summary
Background
A person asked the Court to review a decision from the United States Court of Appeals for the Sixth Circuit and also asked to proceed without paying court fees. The Court granted that request, took the case, and noted the case related to the same legal question that the Court decided in Johnson v. United States about a key sentencing provision in the Armed Career Criminal Act.
Reasoning
The core question was whether the Act’s so-called residual clause—used to increase criminal sentences—was too vague to stand. The Court held the petition, then issued an order vacating the lower-court judgment and sending the case back to the Sixth Circuit for further consideration in light of Johnson, which held that the residual clause is void for vagueness. Justice Alito wrote separately to emphasize that the Court’s order does not decide whether this particular person is entitled to relief on the merits.
Real world impact
Lower courts must now re-examine cases that relied on the residual clause. People sentenced under that clause may get new consideration, but this order itself does not guarantee relief and is not a final decision on individual entitlement. The Court noted it held many similar cases while Johnson was pending, so many appeals will be affected.
Dissents or concurrances
Justice Alito concurred in the Court’s action and stressed that the Court’s decision to vacate and remand does not express any view about whether the petitioner should ultimately receive relief.
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