Nathan Jones v. United States, 16-14922

Nathan Jones pled guilty in 2006 to bank robbery and was sentenced in 2007 to 151 months under a plea agreement; he did not appeal.
The PSR identified multiple prior state felony convictions for violent and drug offenses.
The probation office applied the U.S.S.G. § 4B1.1 career-offender enhancement (crimes of violence + controlled-substance convictions), raising his offense level and producing an advisory range of 151–188 months.
Jones filed a 28 U.S.C. § 2255 motion in 2016 arguing Johnson v. United States invalidated the Guidelines’ residual clause and thus his career-offender enhancement.
The district court dismissed the § 2255 motion; Jones appealed and obtained a COA on whether Johnson applies to the Sentencing Guidelines in light of then-pending Beckles.
The Eleventh Circuit affirmed, holding Johnson does not invalidate the Guidelines’ residual clause in light of circuit precedent and the Supreme Court’s decision in Beckles.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Johnson’s invalidation of the ACCA residual clause requires vacatur of a Sentencing Guidelines career-offender enhancement	Jones: Johnson’s reasoning on vagueness undermines the Guidelines’ residual clause, so his enhancement is invalid	Government: Johnson addressed ACCA; Matchett and Beckles foreclose vagueness challenges to the advisory Guidelines’ residual clause	Court: Rejected Jones; Beckles and Matchett foreclose the claim and the § 2255 motion dismissal affirmed

Johnson v. United States, 135 S. Ct. 2551 (2015) (held ACCA residual clause is unconstitutionally vague)
Welch v. United States, 136 S. Ct. 1257 (2016) (held Johnson announced a new substantive rule retroactive on collateral review)
United States v. Matchett, 802 F.3d 1185 (11th Cir. 2015) (held Johnson does not render the Guidelines void for vagueness)
Beckles v. United States, 137 S. Ct. 886 (2017) (held the advisory Sentencing Guidelines are not subject to vagueness challenges under the Due Process Clause)