Martinez v. United States

Background

A person who had appealed a Ninth Circuit decision asked the Supreme Court for permission to proceed without paying fees and for review. The petition was held pending the Court’s decision in Johnson v. United States, and the Court now acted on that petition.

Reasoning

The Court granted the request to proceed in forma pauperis, agreed to consider the case, vacated the Ninth Circuit’s judgment, and sent the case back for further consideration in light of the Court’s ruling in Johnson. The Court’s order does not decide whether the person is entitled to any relief; instead it directs the appeals court to reevaluate the case under the new guidance from Johnson about the challenged part of the law known as the “residual clause” of the Armed Career Criminal Act.

Real world impact

Lower courts must reconsider cases that relied on the same part of the law addressed in Johnson, which may change outcomes in pending criminal appeals. The Supreme Court’s action here is procedural, not a final decision on the merits, so whether any individual will actually get relief depends on how the appeals court applies Johnson when it reexamines the record.

Dissents or concurrances

Justice Alito filed a short concurrence explaining that the Court’s grant-and-send-back approach treats many similar cases the same way and does not signal any view about whether this particular person should ultimately receive relief.