Lynch v. United States

Background

A person who sought review from the Court asked for permission to proceed without paying fees and asked the Court to consider their appeal from the Eleventh Circuit. The petition was held while the Court decided Johnson v. United States, a case about the meaning of the Armed Career Criminal Act’s so-called "residual clause."

Reasoning

The Court granted the fee request and accepted the petition, then vacated the Eleventh Circuit’s judgment and sent the case back to that court for further consideration in light of the Court’s decision in Johnson. The Johnson decision treated the ACCA residual clause as void for vagueness. The Court’s action here follows the Solicitor General’s recommendation to hold similar petitions pending Johnson.

Real world impact

Appeals courts must now reconsider cases that relied on the ACCA residual clause in sentencing decisions because that clause has been declared void for vagueness. The Court’s decision to vacate and send cases back does not itself decide whether any particular person wins relief; the appeals court must reevaluate each case on its own. Many petitions that were held pending Johnson will move forward for additional review.

Dissents or concurrances

Justice Alito wrote separately to note that the Court has held many petitions pending Johnson and to emphasize that vacating and sending a case back does not signal any view about whether the petitioner will ultimately get relief.