United States v. Copeland

In 2008, Aaron Copeland pled guilty to being a felon in possession of a firearm. The district court imposed an enhanced sentence of 15 years in prison under the Armed Career Criminal Act (“ACCA”) based on his two prior drug offenses and one prior burglary. Copeland did not appeal. After he brought several unsuccessful motions for habeas relief under 28 U.S.C. 2255, the Tenth Circuit authorized Copeland to bring a successive Section 2255 motion to assert that his sentence was invalid under Johnson v. United States, 135 S. Ct. 2551 (2015), which held that the ACCA’s definition of violent felony in its residual clause was unconstitutionally vague. In his motion, Copeland claimed the sentencing court relied on the unconstitutional residual clause to find that his prior burglary was a violent felony and therefore the court should not have enhanced his sentence. The district court denied the motion, finding that it did not sentence Copeland under the residual clause and that his motion accordingly could not rely on Johnson. The Tenth Circuit reversed, finding Copeland showed the district court relied on the residual clause when it sentenced him in 2008. Further, the Court determined Copeland showed he should have prevailed on the merits. View "United States v. Copeland" on Justia Law