Rodney Buckles v. United States
705 F. App'x 886
| 11th Cir. | 2017Background
- Rodney Buckles, a pro se federal prisoner, filed a 28 U.S.C. § 2255 motion seeking to vacate his sentence asserting his career-offender enhancement was invalid.
- The enhancement was based on U.S.S.G. § 4B1.1 (career-offender) and the § 4B1.2(a)(2) residual clause definition of “crime of violence.”
- Buckles argued Johnson v. United States rendered the Guidelines’ residual clause unconstitutional, so his prior convictions (fleeing/attempting to elude; escape) could not qualify.
- The district court denied relief; Buckles obtained a certificate of appealability limited to whether Johnson and Beckles affect the Guidelines’ residual clause.
- The Eleventh Circuit reviewed de novo and affirmed, concluding Johnson does not apply to the Guidelines because the vagueness doctrine does not invalidate advisory sentencing guidelines.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Johnson’s holding (invalidating ACCA residual clause) applies to the Guidelines’ residual clause in § 4B1.2(a)(2) | Johnson renders the Guidelines’ residual clause unconstitutionally vague; Buckles’s prior convictions therefore do not qualify as crimes of violence | Johnson addressed ACCA, not advisory Guidelines; vagueness doctrine does not apply to advisory sentencing guidelines | Court held Johnson does not apply; Beckles confirmed the Guidelines’ residual clause is not void for vagueness, so enhancement stands |
Key Cases Cited
- United States v. Matchett, 802 F.3d 1185 (11th Cir. 2015) (vagueness doctrine does not apply to advisory Guidelines)
- Beckles v. United States, 137 S. Ct. 886 (2017) (Supreme Court: Guidelines are advisory and not subject to vagueness challenge)
- Johnson v. United States, 135 S. Ct. 2551 (2015) (held ACCA residual clause unconstitutionally vague)
- United States v. Lockley, 632 F.3d 1238 (11th Cir. 2011) (distinguishing elements clause and residual clause in Guidelines)
- Tannenbaum v. United States, 148 F.3d 1262 (11th Cir. 1998) (standard of review and liberal construction for pro se filings)
- Murray v. United States, 145 F.3d 1249 (11th Cir. 1998) (limits appellate jurisdiction to issues within COA)