Reinaldo Santos, Petitioner v. United States

Santos asked whether his Florida conviction for battery on a law enforcement officer counts as a violent felony under ACCA (a federal sentence-enhancement law). The Supreme Court granted his petition, set aside the Eleventh Circuit's judgment, and sent the case back for reconsideration in light of the Solicitor General's position rather than answering the ACCA question itself.

The Court granted certiorari (agreed to hear the case), vacated the Eleventh Circuit's judgment, and remanded for further review in light of the Solicitor General's position. Justice Alito dissented, joined by Justice Thomas.

“The judgment is vacated, and the case is remanded to the United States Court of Appeals for the Eleventh Circuit for further consideration in light of the position asserted by the Solicitor General in his brief for the United States filed on March 21, 2019.”

“The Court grants, vacates, and remands in this case, apparently because it harbors...”

This could affect federal defendants whose longer ACCA sentences depend on similar Florida convictions. For Santos, it means the lower court must take another look at whether his prior offense supports the sentencing increase.

The Eleventh Circuit now must revisit the case using the Solicitor General's stated position. The Supreme Court has finished this docket action unless the dispute returns in a later appeal.

Santos argued that his Florida battery conviction should not count as a violent felony under ACCA. That classification affects whether he faces a longer federal sentence.

Defendants with similar Florida convictions may get another chance to challenge ACCA sentence increases. Santos himself gets renewed review in the Eleventh Circuit.

The Eleventh Circuit must reconsider Santos's case in light of the Solicitor General's position. The Supreme Court's work on this docket entry is done for now.