United States v. Lynch, 1:13-cr-00535

Tyrone L. Lynch filed a 28 U.S.C. § 2255 motion challenging his sentence as a career offender under USSG §4B1.2 after a prior §2255 remand based on Johnson v. United States.
At re-sentencing the court treated Lynch as a “career offender” because he had at least two prior convictions qualifying as "crimes of violence" under the Guidelines, which include an elements clause and a residual clause.
Lynch argued one prior conviction counted only under the Guidelines’ residual clause (the “otherwise involves conduct that presents a serious potential risk” language), and that Johnson’s invalidation of the ACCA residual clause required the same result for the Guidelines.
The Sixth Circuit had held in United States v. Pawlak that Johnson’s reasoning invalidated the Guidelines’ residual clause; Lynch relied on that authority and Johnson/Welch retroactivity.
The Supreme Court’s subsequent decision in Beckles held the Guidelines’ residual clause is not subject to vagueness challenges under the Due Process Clause, so Johnson does not invalidate the Guidelines’ residual clause.
The district court denied Lynch’s §2255 motion, finding Beckles dispositive and also noting Lynch waived other claims in his plea agreement; the court did not need to resolve whether Mathis undermined an elements-clause ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Johnson invalidates the Guidelines’ residual clause so Lynch’s career‑offender status is unconstitutional	Lynch: Johnson (and Welch retroactivity) invalidates the Guidelines’ residual clause; prior conviction cannot be counted	Gov: Beckles controls; Guidelines are advisory and not subject to vagueness due process challenge	Denied — Beckles forecloses Johnson challenge to Guidelines’ residual clause; sentence stands
Whether other post‑Johnson changes or case law (e.g., Mathis) alter the court’s conclusion or warrant relief	Lynch: Mathis undermines relying on elements‑clause characterization for one conviction	Gov: Not necessary; even if elements clause uncertain, conviction still qualifies under residual clause per prior analysis	Court declined to resolve Mathis issue because Beckles rendered residual‑clause argument unavailable; plea waiver bars other claims

Johnson v. United States, 135 S. Ct. 2551 (2015) (invalidated ACCA residual clause as void for vagueness)
Welch v. United States, 136 S. Ct. 1257 (2016) (held Johnson rule is substantive and retroactive to cases on collateral review)
United States v. Pawlak, 822 F.3d 902 (6th Cir. 2016) (applied Johnson to invalidate Guidelines’ residual clause in Sixth Circuit)
Beckles v. United States, 137 S. Ct. 886 (2017) (held advisory Sentencing Guidelines are not subject to vagueness challenges; Guidelines’ residual clause not void)
United States v. Anderson, 695 F.3d 390 (6th Cir. 2012) (discussion of attempted felonious assault qualifying under elements clause)
Mathis v. United States, 136 S. Ct. 2243 (2016) (addressed categorical approach and how state statute elements compare to generic offenses)