Price v. United States

Background

A person whose case was decided by the Ninth Circuit asked the Supreme Court to review that decision. The Court allowed the person to proceed without paying fees, agreed to consider the petition, and then held the petition while it decided a related legal question about a clause in a federal criminal law. After that later decision, the Supreme Court vacated the lower-court judgment and sent the case back to the Ninth Circuit for further consideration in light of the new ruling.

Reasoning

The central question was whether a particular clause in the Armed Career Criminal Act is too unclear to be used to increase a sentence. Rather than decide the question on the merits here, the Court followed the Solicitor General’s recommendation to hold and then, after the related decision issued, to vacate and remand the lower-court judgment for fresh review under the new law. The Court made clear that this procedural step does not itself decide whether the person is entitled to relief.

Real world impact

Lower courts, including the Ninth Circuit, must reexamine cases that relied on the same unclear clause and apply the new decision. The opinion notes that many other petitions were held and may similarly be affected. Because the Supreme Court did not rule on the merits in this specific case, the final outcome for the person who brought the challenge could still change after further appellate review.

Dissents or concurrances

Justice Alito wrote separately to emphasize that the Court’s grant-vacate-remand action covers many cases without distinguishing those that might win relief on the merits from those blocked by procedural rules, and he stressed the GVR does not reflect any view on entitlement to relief.