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Courtney Maysv.USA

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.14-13477
DecidedMarch 29, 2016
Reporter703 F.3d 1290
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
CriminalPost-Conviction ReliefHabeas CorpusSentencing GuidelinesStatutory InterpretationReversalRemand
Case Summary

Courtney Mays challenged his federal sentence in a first post-conviction motion. He argued that, after the Supreme Court’s decision in Johnson and the Eleventh Circuit’s application of Descamps, his prior burglary conviction no longer qualified as a violent felony under the Armed Career Criminal Act. The district court denied relief. The Eleventh Circuit held that the relevant decisions applied retroactively in this initial post-conviction proceeding and that the burglary conviction could not qualify under the statute’s enumerated-offenses clause. The court also rejected reliance on the residual clause under the circumstances presented. Because the enhancement produced a sentence longer than the law authorized, the court reversed the denial of Mays’s motion and remanded for resentencing without the challenged enhancement. Judge Jordan concurred in full while noting that the court’s ruling followed the circuit’s existing retroactivity and plain-error decisions. The disposition required a new sentencing proceeding but did not disturb the underlying convictions.

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