United States v. Pickett

The Eleventh Circuit vacated the judgment of the district court granting Defendant relief on a 28 U.S.C. 2255 motion to vacate his sentence, holding that changes to the law since the government’s appeal warranted a remand to the district court where Defendant will have the opportunity to make his case for relief under the new standard.In its original ruling, the district court concluded that, following changes in constitutional law regarding the Armed Career Criminal Act (ACCA), Defendant no longer qualified as an armed career criminal and was not eligible for an enhanced sentence. After the government appealed, the Eleventh Circuit decided Beeman v. United States, 871 F.3d 1215 (11th Cir. 2017), holding that section 2255 movants were required to meet a higher burden that the one the district court applied in Defendant’s case. Applying Beeman to Defendant’s case, the Eleventh Circuit ruled that Defendant did not meet the new standard. The Eleventh Circuit held that because Defendant did not and could not know that he would be required to meet the heightened Beeman standard on appeal, a remand was appropriate. View "United States v. Pickett" on Justia Law