Jones v. United States

2015-06-30
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Headline: Criminal sentencing case sent back: Court vacates Ninth Circuit decision and sends the case for reconsideration after holding part of a federal sentencing law void for vagueness, forcing lower courts to reassess sentences.

Holding: The Court granted review, vacated the Ninth Circuit’s judgment, and remanded for reconsideration in light of Johnson v. United States, which held the sentencing law’s residual clause void for vagueness.

Real World Impact:
  • Requires Ninth Circuit to reconsider the lower-court decision in light of Johnson.
  • Leaves many similar cases open for reconsideration after Johnson.
  • Remand does not guarantee the person will receive relief; appeals court must decide.
Topics: criminal sentencing, vague law rules, appeals and remands, federal criminal cases

Summary

Background

A person who asked the Supreme Court to review a decision from the United States Court of Appeals for the Ninth Circuit had their motion to proceed without paying fees granted and their petition accepted. The Supreme Court vacated the lower court’s judgment and returned the case to the Ninth Circuit for further consideration in light of a recent ruling in Johnson v. United States.

Reasoning

The Court acted because Johnson held that a portion of a federal sentencing law — the so-called residual clause — was void for vagueness. The Court followed the Solicitor General’s recommendation to hold many similar petitions while Johnson was decided, then granted review, vacated the judgment below, and remanded so the appeals court can reconsider the case under the new legal rule. The Court did not decide whether the person asking for review will ultimately get relief.

Real world impact

The immediate effect is that the Ninth Circuit must re-examine the lower-court ruling with Johnson’s ruling in mind. Many other pending cases were also held during Johnson, so more convictions or sentences affected by the same law might be revisited. The remand is not a final grant of relief; the appeals court will decide whether any procedural rules or other reasons still prevent relief.

Dissents or concurrances

Justice Alito wrote separately to stress that the Court did not distinguish between cases where relief would clearly be appropriate and cases that might be blocked for procedural reasons, and that the remand does not signal a view on entitlement to relief.

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