Johnson v. United States, 544 U.S. 295 (2005)
Primary Holding
The period for the 1-year statute of limitations under 28 U.S.C. §2255 begins when a petitioner receives notice of the order vacating a prior conviction used to enhance their federal sentence, provided that the petitioner has pursued the vacatur with due diligence in state court.
In the case of Johnson v. United States, the Supreme Court decided when a person can challenge their federal sentence if a previous state conviction used to increase that sentence is later found invalid. The Court ruled that the one-year time limit for making this challenge starts when the person learns that their state conviction has been overturned, as long as they actively pursued this in state court. This ruling helps protect consumers by ensuring that if someone has a conviction that unfairly affects their federal sentence, they have a clear timeline to seek justice once that conviction is vacated. This case is relevant for anyone who has been sentenced federally based on a state conviction that might not have been valid, giving them a chance to challenge their sentence within the appropriate time frame.
AI-generated plain-language summary to help you understand this case
In 1994, Robert Johnson, Jr. was indicted for distributing cocaine base and related conspiracy charges. He pleaded guilty to a single count of distribution under federal law, which led to a presentence investigation report recommending an enhanced sentence as a career offender due to two prior Georgia convictions for distributing cocaine from 1989. Johnson initially objected to this recommendation but later withdrew his objection during the sentencing hearing. The District Court imposed the enhanced sentence, and judgment was entered on November 29, 1994. Johnson subsequently appealed, arguing for the first time that one of his prior Georgia convictions was invalid. The Eleventh Circuit Court of Appeals affirmed the sentence, noting that Johnson had not previously raised any objections regarding the validity of his prior convictions during the trial. After the appeal, Johnson sought to challenge his federal sentence based on the vacating of one of his state convictions, which he argued had been obtained in violation of his constitutional rights. The Court of Appeals had indicated that if Johnson were to obtain a vacation of the state conviction, he could petition the district court under 28 U.S.C. §2255 for relief. Following the enactment of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), which established a one-year statute of limitations for motions to modify federal sentences, Johnson pursued this route. The legal question before the Supreme Court was when the one-year statute of limitations began to run in cases where a prisoner’s collateral attack on a federal sentence was based on the vacating of a state conviction used to enhance that sentence. The Supreme Court ultimately held that the statute of limitations begins when the petitioner receives notice of the order vacating the prior conviction, provided that he has sought it with due diligence in state court after the entry of judgment in the federal case with the enhanced sentence. This ruling clarified the timing for filing a motion under §2255 in such circumstances.
Whether the 1-year statute of limitations in 28 U.S.C. § 2255 begins to run in a case of a prisoner’s collateral attack on his federal sentence when a state conviction used to enhance that sentence has been vacated.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- January 18, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Souter
- Damages Awarded
- N/A
- Data Quality
- high
Dodd v. United States, 545 U.S. 353 (2005)
Consumer LostThe limitation period for filing a motion under 28 U.S.C. §2255 begins to run on the date the Supreme Court initially recognizes the right asserted, rather than the date the right is made retroactively applicable.
Wilkinson v. Dotson, 544 U.S. 74 (2005)
Consumer WonPrisoners may bring actions under 42 U.S.C. §1983 to challenge the constitutionality of state parole procedures, rather than being required to seek relief exclusively through federal habeas corpus statutes.
Gonzalez v. Crosby, 545 U.S. 524 (2005)
Consumer LostA motion for relief from a judgment in a habeas corpus case, filed under Federal Rule of Civil Procedure 60(b), is subject to the restrictions that apply to “second or successive” habeas corpus petitions under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).
Mayle v. Felix, 545 U.S. 644 (2005)
Consumer LostAn amended habeas petition does not relate back to the date of the original petition under Federal Rule of Civil Procedure 15(c)(2) when it asserts a new ground for relief that is supported by facts differing in both time and type from those in the original pleading, thereby not escaping the one-year limitation period imposed by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).