Walker v. United States
Headline: Vacated and remanded: Court sends case back for reconsideration after ruling that the Armed Career Criminal Act’s residual clause is void for vagueness, affecting cases that relied on that clause.
Holding: The Court granted review, vacated the Eighth Circuit’s judgment, and remanded the case for further consideration in light of Johnson, which held the ACCA residual clause void for vagueness.
- Sends cases relying on the ACCA residual clause back to appeals courts for reconsideration.
- Leaves the final outcome undecided; relief is not presumed for petitioners.
- Applies to many pending cases that were held during the Johnson decision.
Summary
Background
A person seeking review from the Eighth Circuit asked the Court to hear their case and to proceed without paying filing fees. The Court granted that request, held the petition during a related case, and then acted after a new decision about a key part of a federal criminal law.
Reasoning
The Court decided to vacate the judgment below and send the case back to the Eighth Circuit for further consideration in light of Johnson v. United States, which held that the Armed Career Criminal Act’s residual clause is void for vagueness. The Court’s order does not decide the underlying question of whether the petitioner should receive relief; it simply requires the appeals court to reconsider the case with the new rule in mind.
Real world impact
Because the Justices held many similar petitions while Johnson was pending, many cases that relied on the residual clause will be returned to lower courts to be reconsidered. This ruling is procedural: it asks the appeals court to reassess the earlier decision rather than granting definite relief to the person who asked for review. The ultimate outcome for the individual may still change after the appeals court revisits the case.
Dissents or concurrances
Justice Alito wrote a concurring note explaining that the Court’s action to grant, vacate, and remand applies broadly to many cases and does not signal any view on whether the petitioner is entitled to relief on the merits.
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