United States v. Gatson, 1:13-cr-00313

Petitioner Charles Gatson pleaded guilty to being a felon in possession of a firearm and was sentenced on March 10, 2014 to 180 months under the Armed Career Criminal Act (ACCA).
The sentence relied on three prior convictions: one arson conviction and two felony domestic violence convictions, which the Sixth Circuit found qualified as ACCA predicates on appeal.
Gatson’s appeals and petition for certiorari were denied; he then filed a § 2255 motion (filed June 21, 2016) arguing Johnson v. United States required vacatur of his ACCA enhancement.
Johnson invalidated the ACCA residual clause as unconstitutionally vague; Gatson also invoked Mathis in support of his challenge.
The Government moved to dismiss, arguing Gatson’s predicates fell under the ACCA’s enumerated felony and elements (use-of-force) clauses, not the residual clause.
The district court granted the Government’s motion, denied relief under § 2255, and declined to issue a certificate of appealability.

Issue	Gatson's Argument	Government's Argument	Held
Whether Johnson invalidates Gatson’s ACCA enhancement	Johnson and Mathis undermine the predicate analysis so his prior convictions no longer qualify under ACCA	Gatson’s prior convictions qualify under the enumerated-felony (arson) and elements/use-of-force (domestic violence) clauses, so Johnson is inapplicable	Denied — Gatson still qualifies for ACCA enhancement
Whether Mathis provides a basis for relief	Mathis supports narrowing predicate analysis and challenges prior convictions as non-qualifying	Sixth Circuit precedent and post-Mathis decisions confirm Gatson’s convictions remain qualifying	Denied — Mathis does not change result under Sixth Circuit law
Whether reconsideration of the Sixth Circuit’s prior ruling is warranted	Gatson contends precedent changed sufficiently to revisit his enhancement	Government: prior determination tied to enumerated and elements clauses; only residual clause was invalidated	Denied — no extraordinary circumstances to revisit settled appellate findings
Whether a certificate of appealability (COA) should issue	Gatson seeks permission to appeal denial of § 2255 relief	Government opposes; argues Gatson cannot show substantial showing of constitutional denial	Denied — petitioner failed to make the requisite substantial showing

Johnson v. United States, 135 S. Ct. 2551 (2015) (invalidating ACCA residual clause as unconstitutionally vague)
Mathis v. United States, 136 S. Ct. 2243 (2016) (guidance on categorical approach and comparison of elements to statutory offense elements)
United States v. Gatson, 776 F.3d 410 (6th Cir. 2015) (appellate decision finding Gatson’s prior convictions qualified as ACCA predicates)
United States v. Garcia, 496 F.3d 495 (6th Cir. 2007) (preclusion against relitigating matters previously decided absent extraordinary circumstances)
Slack v. McDaniel, 529 U.S. 473 (2000) (standard for issuing a certificate of appealability)
Barefoot v. Estelle, 463 U.S. 880 (1983) (standards referenced for COA substantial-showing review)