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statuteappealfelonyconstitutional law
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Holt v. United States, 843 F.3d 720

Facts

Jakeffe Holt was convicted about a decade ago for possessing a firearm despite having prior felony convictions that prohibited him from gun ownership. The district court classified him as an armed career criminal based on these prior convictions, leading to a 200-month sentence. Following the Supreme Court's ruling in Johnson, which affected the classification of certain felonies, Holt attempted to challenge his sentence under 28 U.S.C. § 2255, arguing that one of his prior convictions should not have counted as a violent felony.

Several of those convictions led the district court to deem him an armed career criminal, 18 U.S.C. § 924(e), and impose a 200-month sentence.

Issue

Whether Holt is entitled to pursue a second collateral attack on his sentence under 28 U.S.C. § 2255.

A second or successive collateral attack is permissible only if the court of appeals certifies that it rests on newly discovered evidence (which Holt’s does not) or 'a new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court, that was previously unavailable.'

Rule

A second or successive collateral attack is permissible only if it rests on newly discovered evidence or a new rule of constitutional law made retroactive by the Supreme Court.

Section 2255(h)(2) therefore does not authorize a second § 2255 proceeding.

Analysis

The court determined that Holt's argument for a second collateral attack did not meet the requirements of § 2255(h)(2) because it was based on the interpretation of the burglary statute rather than a new rule of constitutional law. Although Holt's initial collateral attack might have succeeded, the current argument did not rely on Johnson or any other retroactive rule, thus failing to justify a second proceeding.

Mathis has not been declared retroactive by the Supreme Court—nor is it a new rule of constitutional law.

Conclusion

The Court of Appeals affirmed the lower court's decision, concluding that Holt was not entitled to relief in his second § 2255 proceeding.

It follows that Holt is not entitled to relief in this, his second § 2255 proceeding.

Who won?

The United States prevailed in the case because the court found that Holt's second collateral attack did not meet the necessary legal standards for relief.

While conceding that Holt would prevail in an initial collateral attack, the United States insists that he is not entitled to relief in this second § 2255 proceeding.

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