Langston v. United States
Headline: Court grants review, vacates the judgment, and returns the case to the Eighth Circuit in light of Johnson, potentially affecting sentences tied to the ACCA residual-clause vagueness rule.
Holding: The Court granted the petition, allowed the petitioner to proceed in forma pauperis, vacated the judgment, and remanded the case to the Eighth Circuit for reconsideration in light of Johnson v. United States (2015).
- Sends the case back to the Eighth Circuit for reconsideration under Johnson.
- May affect many pending cases that relied on the ACCA residual clause.
- Does not itself grant the petitioner relief; the appeals court must decide entitlement.
Summary
Background
A person who had been in a case decided by the Eighth Circuit asked the Supreme Court to review that decision. The person was allowed to proceed without paying court fees, and the Court granted the petition for review. The Court then vacated the judgment below and sent the case back to the Eighth Circuit for further consideration in light of a separate decision called Johnson v. United States (2015).
Reasoning
The central question addressed was whether the Court's recent decision in Johnson changes how lower courts should treat a part of the Armed Career Criminal Act known as the residual clause. The Supreme Court followed the Solicitor General’s recommendation to hold similar petitions pending Johnson, and in this case it granted review, vacated the lower judgment, and remanded for reconsideration under Johnson. Justice Alito agreed with that course and emphasized that the Court’s action simply returns the case for reconsideration and does not decide whether the petitioner deserves relief.
Real world impact
The ruling sends the dispute back to the Eighth Circuit to re-evaluate the sentence or conviction in light of Johnson. The decision is procedural and is not a final answer on the merits; the appeals court will determine whether the petitioner receives relief. Many other pending cases were similarly held while the Court decided Johnson, so multiple defendants may get renewed consideration.
Dissents or concurrances
Justice Alito wrote a short concurrence noting the Solicitor General’s role and warning that this GVR does not signal the Court’s view on entitlement to relief.
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