Beckles v. United States, 137 S. Ct. 886

Travis Beckles was convicted of possession of a firearm by a felon (18 U.S.C. §922(g)(1)) and sentenced as a "career offender" under the Sentencing Guidelines §4B1.1 because his offense was treated as a "crime of violence" under the Guidelines' residual clause (§4B1.2(a)(2)).
The Guidelines' residual clause defined "crime of violence" to include offenses that "otherwise involve[] conduct that presents a serious potential risk of physical injury to another." The commentary specifically listed possession of a sawed-off shotgun as a "crime of violence."
Beckles received a Guidelines range of 360 months to life and was sentenced to 360 months; he later sought relief arguing the residual clause was unconstitutionally vague (in light of Johnson v. United States invalidating an identical ACCA residual clause).
Lower courts were divided on whether Johnson's holding about the ACCA residual clause applied to the Sentencing Guidelines' residual clause; the Eleventh Circuit upheld Beckles' sentence on remand, relying on the Guidelines commentary and distinguishing ACCA.
The Supreme Court granted certiorari to resolve the circuit split and address whether the advisory Federal Sentencing Guidelines (specifically §4B1.2(a)'s residual clause) are subject to vagueness challenges under the Due Process Clause.

Issue	Beckles' Argument	United States' Argument	Held
Whether the advisory Sentencing Guidelines' residual clause is void for vagueness under the Due Process Clause	The residual clause in USSG §4B1.2(a)(2) is unconstitutionally vague (like the ACCA clause in Johnson), so Beckles' career-offender enhancement is invalid	The Guidelines are subject to vagueness review (the Government actually agreed), but the Court-appointed amicus argued Guidelines are not amenable to vagueness challenges because they are advisory and do not fix the statutory sentencing range	The advisory Sentencing Guidelines (including §4B1.2(a)'s residual clause) are not subject to vagueness challenges under the Due Process Clause; the residual clause is not void for vagueness

United States v. Batchelder, 442 U.S. 114 (1979) (statutes fixing penalties must specify available punishments; overlapping provisions not void for vagueness where penalties are specified)
Mistretta v. United States, 488 U.S. 361 (1989) (historical account of broad judicial discretion in sentencing and creation of the Sentencing Commission)
United States v. Booker, 543 U.S. 220 (2005) (rendered the Guidelines advisory; affirmed judges' broad discretion within statutory ranges)
Grayned v. City of Rockford, 408 U.S. 104 (1972) (vagueness doctrine protects against lack of notice and arbitrary enforcement)
Kolender v. Lawson, 461 U.S. 352 (1983) (void-for-vagueness principles for criminal laws that fail to give fair notice or invite arbitrary enforcement)
Apprendi v. New Jersey, 530 U.S. 466 (2000) (history of sentencing discretion; significance of statutory sentencing ranges)
Giaccio v. Pennsylvania, 382 U.S. 399 (1966) (vagueness concerns when sentencing leaves judges free to decide without fixed standards)
Rita v. United States, 551 U.S. 338 (2007) (Guidelines as the starting point and benchmark for sentencing)