United States v. Taylor, No. 16-11384 (5th Cir. 2017)
Annotate this CaseThe Fifth Circuit held that defendant's claim that his sentence enhancement was no longer valid under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), was constitutionally based and warranted relief under 28 U.S.C. 2255. As a preliminary matter, the government conceded that defendant's injury to a child conviction no longer counted as an ACCA predicate after Johnson, and that, if defendant's claim was constitutionally based, then his sentence exceeds the statutory maximum. In this case, the district court did not specify under which clause of the ACCA it was sentencing defendant. Texas's injury to a child offense was broader than the ACCA's elements clause, and the injury to a child conviction was necessary to sustain defendant's sentence enhancement because it was one of the three required predicate offenses. The court reasoned that this was sufficient to show that section 924(e)(2)(B)(ii) may no longer authorize defendant's sentence as that statute stands after Johnson v. United States, 135 S. Ct. 2551, 2563 (2015). The court vacated the ACCA enhancement and ordered defendant's immediate release.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.