United States v. Knight
3:06-cr-00144
| E.D. Tenn. | Aug 8, 2017Background
- Knight pleaded guilty in 2007 to being a felon in possession of a firearm (18 U.S.C. § 922(g)(1)) and was sentenced in 2010 to 195 months imprisonment and 5 years supervised release based on ACCA enhancements.
- The PSIR identified six prior Tennessee aggravated burglary convictions as ACCA violent-felony predicates, triggering the 15-year mandatory minimum under 18 U.S.C. § 924(e).
- Knight did not appeal his sentence but filed a § 2255 motion (Descamps-based) in 2014 and a supplemental § 2255 motion (Johnson-based) in June 2016.
- The court deferred ruling pending the Sixth Circuit en banc decision in United States v. Stitt.
- The Sixth Circuit in Stitt held that Tennessee aggravated burglary is broader than generic burglary and therefore is not an ACCA predicate; the parties agreed Knight no longer qualifies as an armed career criminal.
- The district court granted Knight § 2255 relief, reduced his term to time served, and amended supervised release to 3 years, finding his original sentence exceeded statutory limits for a non-ACCA offender.
Issues
| Issue | Knight's Argument | Government's Argument | Held |
|---|---|---|---|
| Whether Knight’s Johnson claim was timely under § 2255(f) | Filed supplemental Johnson claim June 13, 2016, within one-year from June 26, 2015 | Implicitly contended timeliness could be an issue | Timely: Johnson’s one-year clock runs from June 26, 2015; filing falls within window |
| Whether Tennessee aggravated burglary qualifies as an ACCA violent felony | Aggravated burglary predicates relied on ACCA’s residual clause, which Johnson invalidated | Initially relied on Sixth Circuit precedent (Nance) that aggravated burglary was an enumerated predicate | Held: Stitt overruled Nance; Tennessee aggravated burglary is not a violent felony under ACCA; Knight no longer an armed career criminal |
Key Cases Cited
- Johnson v. United States, 135 S. Ct. 2551 (2015) (invalidated ACCA residual clause as unconstitutionally vague)
- Welch v. United States, 136 S. Ct. 1257 (2016) (held Johnson announces a new substantive rule retroactive on collateral review)
- United States v. Stitt, 860 F.3d 854 (6th Cir. 2017) (en banc) (held Tennessee aggravated burglary is not a categorical ACCA burglary predicate)
- Descamps v. United States, 133 S. Ct. 2276 (2013) (articulated categorical approach for determining predicate offenses)
- Dodd v. United States, 545 U.S. 353 (2005) (statute of limitations for collateral claims triggered by date Supreme Court recognizes right)