United States v. Goodridge
392 F. Supp. 3d 159
D.D.C.2019Background
- Ralph A. Goodridge was convicted in 1997 of federal bank robbery (18 U.S.C. § 2113(a)), using/carrying a firearm during a crime of violence (18 U.S.C. § 924(c)), and being a felon in possession (18 U.S.C. § 922(g)).
- The district court sentenced Goodridge to life on Count One under the federal "three strikes" statute (18 U.S.C. § 3559(c)) and life on Count Four under the ACCA (18 U.S.C. § 924(e)), plus ten years consecutive on the § 924(c) count.
- Goodridge obtained First Circuit permission to file a second or successive § 2255 motion based on Johnson v. United States and related doctrine; he challenged the ACCA and § 3559(c) enhancements and the § 924(c) conviction.
- The litigation focused on whether (a) the residual clauses in ACCA/§ 3559(c)/§ 924(c) are void for vagueness post-Johnson/Dimaya/Davis, and (b) Goodridge’s specific prior convictions qualify under the statutes’ force clauses using the categorical/modified categorical approaches.
- The court found the residual clause of § 3559(c) void under Johnson/Dimaya and that, after applying the categorical approach, Goodridge did not have the requisite number of predicate convictions for ACCA or § 3559(c) enhancements, entitling him to resentencing on Counts One and Four.
- The court held Goodridge’s § 924(c) conviction stands because federal bank robbery (§ 2113(a)) (as charged here) is a divisible offense and the form of bank robbery of which he was convicted qualifies as a "crime of violence" under the § 924(c) force clause.
Issues
| Issue | Goodridge's Argument | Government's Argument | Held |
|---|---|---|---|
| Whether ACCA enhancement (Count Four) survives Johnson | Johnson invalidates ACCA residual clause; Goodridge lacks three force-clause predicates | Johnson is retroactive but procedural default bars relief / predicates still qualify | Relief granted: ACCA designation fails; Goodridge has only two ACCA force-clause predicates (ADW counts) → resentencing required |
| Whether § 3559(c) "three strikes" life sentence (Count One) survives Johnson/Dimaya | Residual clause of § 3559(c) is void like ACCA/§16; prior convictions do not meet force clause | Johnson/retroactivity issues; even if residual clause void, some predicates still qualify | Relief granted: § 3559(c) residual clause void; after categorical analysis ABDW, assault-on-guard, armed robbery do not supply two force-clause predicates → resentencing required |
| Whether § 924(c) conviction (Count Two) with bank robbery predicate survives Davis/Johnson | § 924(c) residual clause void; federal bank robbery does not meet force clause categorically | § 2113(a) (as charged) is divisible and the intimidation/force variant qualifies under force clause; precedents bind court | Relief denied as to Count Two: § 2113(a) conviction here (force/intimidation variant) is a crime of violence under § 924(c)(3)(A) → § 924(c) conviction remains |
| Procedural default and availability of successive § 2255 relief | Johnson/Dimaya are novel rules that excuse procedural defaults and satisfy § 2255(h)(2) gatekeeping | Government contested procedural default and § 2255(h)(2) applicability for non-ACCA statutes | Court found cause and prejudice: Johnson/Dimaya are novel and retroactive, so § 2255 relief was procedurally available for ACCA and § 3559(c) claims |
Key Cases Cited
- Johnson v. United States, 135 S. Ct. 2551 (2015) (ACCA residual clause is unconstitutionally vague)
- Sessions v. Dimaya, 138 S. Ct. 1204 (2018) (residual-clause vagueness principle applied to § 16(b))
- United States v. Davis, 139 S. Ct. 2319 (2019) (§ 924(c)(3)(B) residual clause is unconstitutionally vague and categorical approach required)
- Welch v. United States, 136 S. Ct. 1257 (2016) (Johnson rule is retroactive on collateral review)
- United States v. Starks, 861 F.3d 306 (1st Cir. 2017) (Massachusetts armed robbery not categorically a violent felony under ACCA force clause)
- United States v. Whindleton, 797 F.3d 105 (1st Cir. 2015) (Massachusetts ADW has elements satisfying ACCA force clause)
- United States v. Hunter, 873 F.3d 388 (1st Cir. 2017) (federal bank robbery under § 2113(a) can be a crime of violence under § 924(c) force clause)
- United States v. Ellison, 866 F.3d 32 (1st Cir. 2017) (analysis of § 2113(a) intimidation prong having threatened use of physical force)
- United States v. Faust, 853 F.3d 39 (1st Cir. 2017) (assault and battery on officer encompasses non-violent offensive battery; not categorically a violent felony)
- United States v. Kennedy, 881 F.3d 14 (1st Cir. 2018) (Massachusetts ABDW has intentional and reckless forms; only intentional may qualify under force clause)