Shea v. United States, No. 17-1899 (1st Cir. 2020)
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The First Circuit vacated the district court's judgment denying Defendant's motion to vacate his 18 U.S.C. 924(c) conviction and to resentence him without a career offender enhancement, holding that because Johnson v. United States, 576 U.S. 591 (2015) established that the U.S. Sentencing Guidelines' residual clause before United States v. Booker, 54 U.S. 220 (2005), was decided was too vague to constitutionally enhance a defendant's sentence, Defendant's claims were timely.
Defendant was convicted under section 924(c). The judge classified Defendant as a career offender under section 4B1.1 of the guidelines. Thereafter, the Supreme Court decided Booker, which held that the mandatory Guidelines system was unconstitutional. Thereafter, the Supreme Court announced a new rule of law in Johnson that imposing an increased sentence under the residual clause of the Armed Career Criminal Act is unconstitutionally vague. Defendant moved to vacate his conviction and sentence, arguing that the Court's reasoning in Johnson made similar residual clauses in section 942(c) and section 4B1.2(a) unconstitutionally vague as well. The district court denied the motion. The First Circuit vacated the judgment, holding (1) Johnson dictates that 4B1.2(a)'s residual clause is unconstitutionally vague; and (2) as a result, Defendant asserted the same right newly recognized in Johnson, making his petition timely.
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