United States v. Taylor
672 F. App'x 860
| 10th Cir. | 2016Background
- Eric Jackson Taylor pleaded guilty (2001) to being a felon in possession of a firearm; government dismissed other counts.
- At sentencing the district court applied the ACCA, relying on three Oklahoma second‑degree burglary convictions, and imposed 188 months.
- Taylor filed a § 2255 motion (2016) asserting Johnson v. United States invalidated his ACCA enhancement.
- The district court denied relief, finding Johnson only invalidated the ACCA residual clause and did not affect enumerated offenses like burglary.
- On appeal Taylor invoked Mathis v. United States (decided after the district court’s denial) arguing Oklahoma’s burglary statute is broader than generic burglary and thus cannot serve as an ACCA predicate.
- The Tenth Circuit considered (1) whether Mathis alters the Johnson analysis and (2) whether Mathis supplies a new, retroactive rule enabling collateral relief under § 2255(f)(3).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Johnson invalidates Taylor’s ACCA enhancement | Johnson voids ACCA’s residual clause; Taylor’s priors no longer qualify | Johnson only invalidates the residual clause; enumerated offenses (burglary) remain valid ACCA predicates | Court: Johnson does not help Taylor; district court correctly rejected Johnson‑based relief |
| Whether Mathis undermines use of Oklahoma second‑degree burglary convictions as ACCA predicates | Mathis shows statutes that list broader places than generic burglary cannot qualify; Oklahoma statute is broader, so Taylor’s priors are not ACCA predicates | Government: Mathis decided after district court; but if Mathis were applicable it would affect predicate analysis | Court: Mathis analysis would preclude using Oklahoma burglary convictions as ACCA predicates (district court’s modified categorical approach was erroneous) |
| Whether Mathis creates a new right for collateral review under § 2255(f)(3) | Taylor contends Mathis supplies a newly recognized Supreme Court rule that is retroactive and triggers the one‑year window | Government argues Mathis did not announce a new rule and thus is not retroactive to convictions final long ago | Court: Mathis did not announce a new rule; its result was dictated by precedent, so it is not retroactive for collateral review; Taylor’s petition is time‑barred |
| Whether a COA should issue for Taylor’s appeal of the § 2255 denial | Taylor seeks a COA to appeal denial | Government opposes COA | Court: Denied COA; reasonable jurists would not debate the district court’s denial under applicable retroactivity rules |
Key Cases Cited
- Johnson v. United States, 135 S. Ct. 2551 (2015) (invalidated ACCA residual clause; did not disturb enumerated offenses)
- Mathis v. United States, 136 S. Ct. 2243 (2016) (explains categorical approach; statutes broader than generic offense cannot qualify as ACCA predicates)
- Teague v. Lane, 489 U.S. 288 (1989) (framework for retroactivity of new rules on collateral review)
- Miller‑El v. Cockrell, 537 U.S. 322 (2003) (certificate of appealability standard)
- Slack v. McDaniel, 529 U.S. 473 (2000) (standard for assessing whether reasonable jurists would debate denial of habeas relief)