United States v. Webb, 217 F. Supp. 3d 381

Webb and Meadows were convicted of being a felon in possession of a firearm (18 U.S.C. § 922(g)(1)) and sentenced as armed career criminals (ACCA, 18 U.S.C. § 924(e)) based on prior state convictions.
Webb's predicates included multiple drug convictions and Massachusetts assault and battery by means of a dangerous weapon (ABDW) and larceny from a person; the government conceded larceny no longer qualifies as a violent felony.
Meadows's predicates included Massachusetts arson (burning a dwelling), ABDW, and armed robbery while masked.
After Johnson v. United States and Welch (holding the ACCA residual clause void and retroactive), both filed successive 28 U.S.C. § 2255 motions arguing some predicates no longer qualify as "violent felonies."
The court excused procedural default (cause and prejudice) based on Johnson and related precedent, then evaluated whether each predicate conviction qualifies under the ACCA force clause or as an enumerated offense.
Court held Massachusetts ABDW qualifies as a violent felony under the ACCA force clause; Massachusetts arson (as charged under an indivisible statute including aiding/counseling/procuring) is overbroad and does not match generic arson, so Meadows is entitled to resentencing while Webb is not.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether procedural default is excused for §2255 claims after Johnson	Both petitioners: Johnson/Welch created novel, retroactive rule excusing default	Government: prior unsuccessful challenges defeat novelty; no cause	Court: excused default — Reed categories and Johnson/Welch satisfy cause and prejudice for these claims
Whether Massachusetts ABDW is a "violent felony" under ACCA force clause	Petitioners: ABDW overbroad (de minimis touching; may be reckless)	Government: dangerous-weapon element supplies violent force; recklessness qualifies after Voisine	Court: ABDW qualifies as violent felony (dangerous-weapon element + recklessness suffices)
Whether Massachusetts arson (burning a dwelling) is a generic "arson" predicate	Meadows: statute is indivisible and overbroad because it includes aiding/counseling/procuring without mens rea as to burning	Government conceded arson not a force-clause issue	Court: Massachusetts arson overbroad vs. generic arson (indivisible statute sweeps beyond willful/malicious burning) — not a predicate
Remedy: Whether each petitioner loses ACCA status and is entitled to relief	Webb: losing larceny and one vacated drug conviction leaves ACCA count intact because ABDW remains a predicate	Meadows: arson no longer counts, dropping him below ACCA threshold	Court: Denied relief to Webb; granted §2255 relief to Meadows and ordered resentencing

Johnson v. United States, 135 S. Ct. 2551 (U.S. 2015) (ACCA residual clause is unconstitutionally vague)
Welch v. United States, 136 S. Ct. 1257 (U.S. 2016) (Johnson announced a new substantive rule retroactive on collateral review)
Reed v. Ross, 468 U.S. 1 (U.S. 1984) (when novelty of rule can supply cause to excuse procedural default)
Bousley v. United States, 523 U.S. 614 (U.S. 1998) (actual innocence and cause/prejudice framework for procedural default)
Descamps v. United States, 133 S. Ct. 2276 (U.S. 2013) (categorical and modified categorical approaches for predicate offenses)
Mathis v. United States, 136 S. Ct. 2243 (U.S. 2016) (divisible vs. indivisible statutes and limits on Shepard documents)
Leocal v. Ashcroft, 543 U.S. 1 (U.S. 2004) (mens rea floor for "use of physical force" analysis)
Voisine v. United States, 136 S. Ct. 2272 (U.S. 2016) (reckless misdemeanor domestic violence involves use of physical force; informs recklessness question)
Begay v. United States, 553 U.S. 137 (U.S. 2008) (residual-clause analysis requiring similarity in kind and purposefulness)
Castleman v. United States, 134 S. Ct. 1405 (U.S. 2014) (interpretation of "force" differs between misdemeanor and felony contexts)