Smith v. United States
Headline: Court vacates and sends back a criminal sentence appeal for reconsideration in light of Johnson, affecting defendants sentenced under the Armed Career Criminal Act’s disputed residual clause.
Holding:
- Requires lower courts to reconsider sentences tied to the ACCA residual clause.
- May lead to sentence changes for defendants convicted under that provision.
- Does not automatically grant relief; lower courts must decide who benefits.
Summary
Background
A person who had appealed a federal sentence asked the Supreme Court to review a decision from the Eleventh Circuit. The petitioner also sought permission to proceed without paying court fees. The case centers on the Armed Career Criminal Act and a challenged portion called the “residual clause.” The Supreme Court held the petition, granted review, vacated the lower-court judgment, and sent the case back to the Eleventh Circuit for further consideration in light of the Court’s decision in Johnson v. United States.
Reasoning
The central question was whether the lower court’s decision should stand after the Supreme Court’s ruling in Johnson about the residual clause. Rather than decide the defendant’s entitlement to relief on the merits, the Court vacated the judgment and remanded the case so the appellate court can reconsider the issues under Johnson. The Court’s order follows the Solicitor General’s recommendation to hold similar cases pending the Johnson decision.
Real world impact
Lower federal courts must now reexamine cases that relied on the residual clause of the Armed Career Criminal Act and determine whether defendants are entitled to relief after Johnson. That reexamination may lead to changes in some sentences, but the Supreme Court’s order does not itself grant relief or say which defendants should win. The decision may affect many pending appeals.
Dissents or concurrances
Justice Alito wrote a short concurrence explaining that the Court’s action is procedural and does not express a view about whether this particular petitioner deserves relief.
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