D.C. Circuit - Categorical Approach

United States v. Arrington, 4 F.4th 162 (D.C. Cir. 2021). The Supreme Court’s decision in United States v. Johnson, 153 S. Ct. 2551 (2015) (holding that the ACCA’s residual clause was unconstitutionally vague), initially recognized petitioner’s claim that the residual clause contained in the pre-Booker Guidelines is unconstitutionally vague and thus restarts the limitations period for raising this claim in a § 2255 motion.

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