Washington v. United States
868 F.3d 64
| 2d Cir. | 2017Background
- Ronnie Washington, convicted in 2011 of federal narcotics offenses, was sentenced as a Guidelines career offender under § 4B1.1 to 240 months.
- Washington previously pursued and lost a § 2255 motion in 2014 challenging his career-offender designation.
- He sought leave to file a successive § 2255 motion arguing Mathis v. United States rendered his career-offender enhancement unconstitutional.
- Washington did not assert newly discovered evidence; his claim rested on Mathis as announcing a new rule of constitutional law.
- The Second Circuit treated the filing as a successive collateral attack subject to § 2255(h) and analyzed whether Mathis qualifies under § 2255(h)(2).
- The court concluded Mathis was an exercise in statutory interpretation of the ACCA and not a new constitutional rule, so it denied leave to file a successive § 2255 motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Mathis announced a new, retroactive rule of constitutional law under 28 U.S.C. § 2255(h)(2) permitting a successive § 2255 | Mathis established a new constitutional rule making Washington's career-offender enhancement unconstitutional | Mathis is statutory interpretation of ACCA, not a new constitutional rule; it does not satisfy § 2255(h)(2) | Denied: Mathis is not a new constitutional rule; successive motion impermissible |
Key Cases Cited
- Mathis v. United States, 136 S. Ct. 2243 (2016) (interpreting ACCA; elements-based approach required where statute lists alternative means)
- Taylor v. United States, 495 U.S. 575 (1990) (elements-based categorical approach for predicate offenses)
- Shepard v. United States, 544 U.S. 13 (2005) (limited documents may be consulted to identify the offense of conviction)
- Descamps v. United States, 133 S. Ct. 2276 (2013) (limits on using the modified categorical approach)