United States v. Snyder, No. 14-6023 (10th Cir. 2015)
Annotate this CaseDefendant-appellant John Snyder was stopped for a traffic offense and, upon approaching the vehicle, the investigating officer smelled the odor of burnt marijuana. Officers then searched his car and discovered a firearm under the driver's seat, which Snyder admitted was his. Snyder was convicted for unlawful possession of the firearm and because of a number of previous felony convictions, received a lengthy 180-month sentence under the Armed Career Criminal Act's (ACCA) mandatory minimum sentencing provision. On appeal, Snyder argued: (1) his vehicle was searched without probable cause in violation of the Fourth Amendment; and (2) the ACCA's residual clause was unconstitutionally vague, and applying it to increase his sentence violated due process. The Tenth Circuit concluded: (1) the smell of burnt marijuana was sufficient to establish probable cause for a vehicle cabin search; and (2) the residual clause of the ACCA was controlled by the U.S. Supreme Court's decision in "Johnson v. United States," which held that the statute's residual clause was void for vagueness. As a result, the Court remanded for the district court to vacate Snyder's sentence, and to re-sentence him.
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