No. 25-7615October Term 2025Before Arguments
Jonathan Wayne Lanaute, Petitioner v. United States
from the United States Court of Appeals for the Fifth Circuit.
Case status
- Current stage
- Before Arguments
- Latest event
- Accepted by the Court
- Decision timing
- No window until argument is scheduled.
- What it's about
from the United States Court of Appeals for the Fifth Circuit.
Question presented
Whether a defendant challenging a prior state conviction under the crime-of-violence force clause must produce an actual state-court decision applying a facially overbroad statute to non-generic conduct—as the Fifth Circuit alone requires—or whether the statutory text and elements suffice to demonstrate overbreadth—as every other circuit holds?
- Case path
United States Court of Appeals for the Fifth Circuit / Accepted by the Court
- Area
Supreme Court case awaiting argument
Timing
Expected by late June 2026, if argued this term
The Court granted review but has not yet scheduled oral argument. Once argued, the median case reaches a decision in 94 days. Nearly all cases are decided by the end of the term in which they are argued.
Briefing
What it's about
Jonathan Wayne Lanaute has asked the Supreme Court to review a Fifth Circuit rule for challenging a prior state conviction under the crime-of-violence force clause. The dispute is whether a defendant must point to a real state-court case applying an overbroad statute to non-generic conduct, or whether the statute's text and elements alone can show overbreadth.
Argument
The case is still at the petition stage, and oral argument has not been scheduled. The petition says statutory text and elements should be enough to show overbreadth, while the Fifth Circuit requires an actual state-court decision applying the statute to non-generic conduct.
Impact
The answer could shape how hard it is for defendants to contest the use of older state convictions in federal court. For example, someone in the Fifth Circuit may face a tougher burden than defendants in other circuits when trying to show a prior conviction should not count.
What is the dispute in Lanaute v. United States?
It asks whether a defendant must find a real state-court case showing a broad statute used in a non-generic way. Or whether the statute's text and elements alone can show overbreadth.
Who could be affected if the Court takes Lanaute?
Defendants with prior state convictions, especially in the Fifth Circuit, could be affected. A stricter proof rule can make it harder to challenge whether an earlier conviction counts.
What happens next in Jonathan Wayne Lanaute v. United States?
The Court must decide whether to grant certiorari (hear the case). Oral argument has not been scheduled, and no decision window is available yet.
Related cases




Grounding
- Grounding
- Primary materials plus reporting.
- Note
- Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
- Checked
- Jul 17, 2026
- Method
- Methodology