Mayer v. United States

Background

A person who challenged a federal sentence asked the Supreme Court to review a Ninth Circuit decision. The Court granted the request, allowed the person to proceed without paying fees, and then vacated the lower court’s judgment. The opinion says the case should be reconsidered in light of a new Supreme Court decision in Johnson v. United States about the Armed Career Criminal Act’s so-called "residual clause."

Reasoning

The main question was whether the lower court’s ruling should stand after the Johnson decision called the residual clause into question. The Supreme Court did not decide the underlying claim on the merits. Instead, the Court granted review, vacated the Ninth Circuit’s judgment, and remanded the case to that court for further consideration in light of Johnson. The Court’s action was a procedural step to have the lower court reevaluate the case under the new ruling.

Real world impact

Because the Court said many petitions were held pending Johnson, this vacate-and-remand approach affects cases involving the same federal sentencing provision. The Ninth Circuit must now reconsider the case under the new guidance. The Supreme Court’s order does not itself decide whether the person challenging the sentence should get relief, so the outcome could change on rehearing.

Dissents or concurrances

Justice Alito wrote separately to emphasize that the Court has not distinguished between cases where relief would follow if the clause is voided and cases where relief might be blocked for procedural reasons, and that the remand does not indicate any view about the person’s entitlement to relief.