Taste v. United States

2015-06-30
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Headline: Federal sentencing dispute vacated and sent back: Court grants review, vacates the Fourth Circuit’s judgment, and remands for reconsideration in light of Johnson, affecting cases about the Armed Career Criminal Act’s residual clause.

Holding:

Real World Impact:
  • Sends the case back to the appeals court for reconsideration under Johnson.
  • Affects other cases tied to the Armed Career Criminal Act’s residual clause.
  • Does not guarantee relief; the appeals court must decide if relief is warranted.
Topics: federal sentencing, criminal appeals, vague criminal laws, Armed Career Criminal Act

Summary

Background

An individual asked the Supreme Court to review a Fourth Circuit ruling and sought permission to proceed without paying court fees. The Court granted the request to proceed in forma pauperis and accepted the petition for review. The dispute reached the Court after a lower-court judgment about a federal sentencing issue connected to the Armed Career Criminal Act’s so-called residual clause.

Reasoning

The central question was whether the lower court’s decision should stand after the Court’s decision in Johnson v. United States, which addressed the residual clause of the Armed Career Criminal Act. The Supreme Court granted review, vacated the Fourth Circuit’s judgment, and sent the case back to that appeals court to reconsider the case in light of Johnson. The Court’s action was procedural: it did not decide whether the person challenging the sentence must receive relief on the merits.

Real world impact

This disposition sends the case back to the appeals court for fresh consideration under the reasoning in Johnson and could change outcomes for people sentenced under the residual clause. The ruling is not a final decision about guilt or sentence; it only requires the lower court to reexamine the case. Several other cases were held or treated similarly pending the Johnson decision, meaning many appeals may be affected.

Dissents or concurrances

Justice Alito wrote separately to stress that vacating and remanding does not signal the Supreme Court’s view about whether the petitioner deserves relief, and that the Court did not distinguish between cases that would or would not warrant relief on procedural grounds.

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